FSMA Final Rule on Requirements for Additional Traceability Records for Certain Foods Archives

Passed in 2011, the Food Safety and Modernization Act (FSMA) is transforming the U.S. food supply chain. The law applies to most members of the food supply chain, including harvesters, coolers, packers, processors, distributors, and retail food establishments. The deadline to comply with the regulations, including the Final Rule on Requirements for Additional Traceability Records for Certain Foods, is January 20, 2026.

As the deadline approaches, it’s vital to ensure you’re making preparations to comply. Though this definitely includes rules regarding harvesting and transportation it’s important to remember that FSMA also addresses food storage and warehousing. With that in mind, let’s take a deep dive into FSMA warehouse requirements and what they mean for your business.

Understanding FSMA Warehouse Requirements

FSMA includes a set of rules that govern food production and distribution. FSMA 204, the Food Traceability Final Rule, established additional traceability recordkeeping requirements for persons who manufacture, process, pack, or hold foods included on the Food Traceability List (FTL).

There are seven other rules, some that could affect operations and compliance at your warehouses and other facilities:

- - Preventive Controls for Human Food: Must meet Current Good Manufacturing Practice mandates, perform hazard analyses, and implement preventive controls.
  - Produce Safety Rule: Must establish science-based standards for packing, production, and storage of fruits and vegetables
  - Foreign Supplier Verification Program (FSVP): Requires foreign suppliers to demonstrate that they are meeting U.S. food safety standards
  - Sanitary Transportation Rule: Establishes regulations for sanitary transportation of food items
  - Accredited Third-Party Certification Rule: Created a program to accredit specific third-party certification bodies to conduct food safety system audits of foreign facilities.
  - Protection Against Intentional Adulteration: Aims to prevent foodborne illness by guarding against intentional adulteration
  - Voluntary Qualified Importer Program (VQIP): Optional fee-based program for foreign food facilities that want to import foods into the U.S.

We know it can be challenging to understand the FSMA rules. While focusing on the totality of the regulations — how they’ll affect your operations, your trading partners, the industry in general, and even consumers — always pay attention to the rules that pertain to your specific, day-to-day role in the supply chain.

For instance, if you operate food warehouses, be sure you understand the FSMA storage regulations just as well as you understand the FSMA 204 traceability requirements.

FSMA Warehouse and Storage Regulations

The primary goal of the FSMA regulations is to prevent foodborne illnesses and protect public health. Though this is the main driver for compliance, keep in mind that non-compliance can slow or stop your operations, damage to your brand reputation, and irk your customers and consumers.

With this in mind, here are the basics of FSMA warehouse requirements:

- - Pest Control: Food safety plans must protect food items from indoor and outdoor pests
  - Sanitation: Consumers must be protected from allergen cross-contact and pathogens
  - Temperature Controls: Especially important for animal foods like meat, eggs, and milk

Additionally, you’ll need to meet the FSMA 204 traceability requirements. Read more about those in our blog here.

Implications for Distributors

If you’re a distributor, FSMA warehouse and storage requirements directly affect your operations. The law requires you to keep and maintain records that show you and your partners are compliant and adhering to food safety requirements. This means you should be coordinating with your partners right now to make sure they’re preparing to share information and comply.

You’ll also need to closely monitor warehouse operations. Pay close attention to refrigeration guidelines, and take corrective actions immediately if you detect a deficiency. Also make sure you have the right sanitation controls in place, as this will help prevent cross-contamination.

Key Practices for Compliance

So what can you do to comply with FSMA? Beyond contacting us to discuss the requirements and the concrete steps you can take now, here’s a short list of things to keep top of mind:

Create a Food Safety Culture through Training

Your team is the first line of defense against outbreaks and compliance slip-ups, so make sure they have a foundational knowledge of the law. A well-trained team can help you be prepared for FSMA warehouse requirements and keep your facilities safe, compliant, and efficient. Training should include FSMA basics — traceability, modernization, food safety, etc. — as well as information about food processing best practices and your organizational commitment to safety and compliance.

Audit Your Processes

One key to compliance is to be audit-ready. The USDA or FDA may never come knocking, but you should act like it’s an inevitability. Conduct your own audits to identify compliance gaps in your storage and distribution processes. Internal audits will also reveal pain points and other inefficiencies that affect your operations.

Implement a Robust Recordkeeping System

FSMA stipulates that supply chain actors must maintain and share product information with their partners. The law also says that companies must share records with the FDA within 24 hours of a request (or within a mutually agreed-upon timeframe). If should you be audited, expect repercussions if you don’t have the required traceability information on hand.

Have a Plan for Safety — and More

Create a food safety plan and share it with your team. Anyone involved in maintaining food safety and preventing foodborne illness should know your plan inside and out.

You should also create a recall strategy. This should include how to share information with the FDA and other authorities and your trading partners. It should also include how to communicate with consumers about affected products and how to dispose of them safely.

Final Thoughts: Be Proactive with FSMA Warehouse Requirements

The best and quickest path to complying with FSMA warehouse requirements is to work with a reliable, experienced technology provider like us. Our supply chain solutions for the food and beverage industry will ensure you’re ready for January 2026 and the FSMA regulations for traceability, storage, and recordkeeping.

Connect with us today and one of our FSMA compliance and supply chain traceability experts can show you how it works. In about 15 minutes, you’ll have a better understanding of the law, how prepared you are, and how to get to full compliance by January 2026.

The Food Safety and Modernization Act (FSMA) is the most significant development in food industry traceability. One specific set of requirements in the law, the Final Rule on Requirements for Additional Traceability Records for Certain Foods, is reshaping and modernizing the approach to food safety and food supply chain data.

Whether you’re a grower, processor, distributor, or retailer in the food industry, understanding and implementing FSMA traceability is vital. Let’s walk through FSMA traceability requirements so you can adapt to the FDA’s Food Traceability Final Rule and ensure your compliance.

What Is FSMA Traceability?

FSMA traceability refers to the ability to track every step of a food product’s journey from farm to table, as required by the law. It’s primary goal is to help prevent and mitigate foodborne illnesses

FSMA traceability requirements center around creating, maintaining, and sharing a clear record of where food comes from, where it was, where it is now, where it’s going, and who’s handling it.

Under FSMA, the Food Traceability Final Rule defines additional recordkeeping requirements all those who manufacture, process, pack, or hold foods on the Food Traceability List (FTL), which includes cheeses, shellfish, and certain fruits and vegetables. It provides you and your trading partners with clear guidance on what data you must keep and share as your products move across your supply chain.

The FDA’s Role in FSMA Traceability

The Food and Drug Administration plays a pivotal role in FSMA traceability: It sets FSMA traceability requirements, evaluates foods using a risk-ranking model, and holds stakeholders accountable for complying with the act. In addition to setting traceability recordkeeping requirements, the FDA also assesses penalties for non-compliance with the traceability program.

Compliance Requirements for Food Industry Professionals

FSMA 204 and other provisions of FSMA apply to:

Harvesters
Coolers
Packers
Processors
Distributors
Retail food establishments

The specific requirements for your business will vary based on your role in the food supply chain. Many requirements focus on initial packing and labeling; proper packaging and labeling promote FSMA traceability and streamline the flow of goods along the supply chain.

FSMA 204 also requires using traceability lot codes, developing a traceability plan, and sharing records with the FDA when requested.

Benefits of FSMA Traceability

Embracing traceability promotes better food safety and protects consumers from foodborne illnesses. If an issue arises with one of your products, you can use traceability data to quickly find where it came from and where it is now. This granular, read-time information expedites recalls and ensures that all affected products are removed from store shelves as quickly as possible.

From a business perspective, FSMA 204 helps you protect your brand image, as you can ensure the quality, integrity, and safety of food products. In addition to enhancing your reputation, you can use FSMA traceability to identify bottlenecks within the supply chain and eliminate waste.

Technology and Tools for FSMA Traceability

FSMA gives the FDA the authority to establish modern, science- and risk-based requirements, including all the traceability requirements in Section 204.

The law dovetails with the Agency’s New Era of Smarter Food Safety, which is “a new approach to food safety, leveraging technology and other tools and approaches to create a safer and more digital, traceable food system.” It will the FDA identify ways to further its modernization goals and help ensure that the regulations evolve with the industry and available technology to reduce foodborne illness.

So, what we’re seeing with FSMA 204 is part of the FDA’s plan to secure the food supply chain using technology. FSMA traceability, anchored by requirements for food companies to record and share Critical Tracking Events (CTEs) and Key Data Elements (KDEs), is attainable with currently available digital supply chain technology.

Other requirements, such as using traceability lot codes and having systems to share electronic sortable spreadsheets with traceability information to the FDA, are also part of a strategic approach to leveraging technology for FSMA compliance.

Food supply chain traceability software is the best road to meeting technological requirements and FSMA compliance. It’s also the best way to ensure you remain compliant and competitive as regulations, food trends, and consumer attitudes evolve.

Common FSMA Traceability Challenges

Challenges to complying with FSMA traceability regulations include the following:

Integrating traceability systems with existing processes: Adding any new tech tool to your established systems/process could disrupt operations, including interactions with trading partners.
Ensuring your partners are preparing: Traceability requires participation from everyone in the supply chain. Talking with your trading partners about FSMA readiness is vital to being ready to comply by the January 2026 deadline.
Training staff: You’ll need to educate and train staff on FSMA 204 compliance and the effect it will have on your business. Training is also necessary to create a culture of food safety in your organization.
Managing data: Complying with FSMA means you will be creating, sharing, accessing, and storing massive amounts of data. Your systems not only have to handle the volume — they must ensure the data is compliant.

Navigating the challenges requires a holistic approach. First and foremost, you need to get your team on board by being transparent about the regulations, how they will affect your daily operations, people’s roles and responsibilities, and what you are doing to prepare.

The Importance of Data Security and Privacy

With so much sensitive data being generated, security and privacy are paramount. You need to make sure that your traceability data is protected from unauthorized access and breaches. This means investing in secure systems and being mindful of privacy laws and regulations.

Additionally, you must ensure that your partners are doing their part to promote data security. Remember, you’ll need to integrate some of your technologies with theirs to expedite the flow of traceability data. You don’t want to inadvertently create a blind spot or weak link in your data infrastructure by partnering with a vendor that does not take data security as seriously as you do.

Anticipating Regulatory Audits

Nobody wants to be audited, but everybody should be prepared. The key to passing an audit is to make food safety and FSMA compliance part of your company culture. If these are only afterthoughts or simply a box to check, the chances of failing an audit are much higher. In contrast, being proactive means an audit will essentially be a formality (and become an opportunity to stand out among competitors).

Final Thoughts: FSMA Traceability with rfxcel

Familiarizing yourself with FSMA traceability requirements will help you achieve and maintain compliance, improve food safety, and preserve your brand image. Prioritize compliance and implement effective traceability practices by partnering with rfxcel. We’ve been a leader in traceability (and compliance) technology for 20 years, and we will work with you to develop a solution suited to your needs.

Book a demo to learn more. We also invite you to explore our other FSMA resources.

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FSMA Warehouse Requirements: A Comprehensive Guide for Compliance