As the compliance deadline for Section 204 of the Food Safety Modernization Act (FSMA) approaches, grocers face significant changes in how they manage food traceability. This legislation, set to take effect on January 20, 2026, aims to enhance supply chain transparency and rapidly identify contaminated products. Retailers must now prepare for financial, operational, and legal challenges while leveraging this opportunity to improve customer trust and operational efficiency.

Empowering Grocers to Lead in Transparency and Safety

The Scope of FSMA's New Requirements

The new regulations mandate detailed record-keeping for specific high-risk foods listed in the Food Traceability List (FTL). Items such as soft cheeses, sprouts, tomatoes, crustaceans, and mollusks require meticulous documentation of Key Data Elements (KDEs). These records must be available within 24 hours of a request from the Food and Drug Administration (FDA), ensuring rapid response to potential contamination incidents. Retailers are tasked with maintaining KDEs throughout the entire supply chain journey—from suppliers to distribution centers and finally to stores and restaurants. For instance, data elements like traceability lot codes and product descriptions can be printed on labels, while other details, such as receipt dates, need to be recorded manually. Companies must store these records for two years, underscoring the importance of robust data management systems.

Navigating Supplier Collaboration and Compliance

Grocers and wholesalers face the challenge of ensuring that suppliers can meet the new traceability requirements. If suppliers lack the technical capability to provide necessary data, retailers must develop alternative methods for collecting this information. This includes reviewing case labels and informing suppliers about the critical need for accurate lot code information. Moreover, retailers with central kitchens or those producing deli items across multiple locations will need to implement additional data tracking measures. Creating new traceability lot codes for transformed food items is essential to comply with the regulations. Implementing these changes requires a phased approach: supplier onboarding for data sharing, traceability at the distribution center, and finally, at the store level. Each phase demands careful planning and coordination to ensure seamless compliance.

Embracing Traceability as a Competitive Advantage

Food traceability has evolved beyond mere regulatory compliance; it now represents a competitive edge. Leading retailers like Kroger, Albertsons, and Walmart have implemented traceability programs that surpass FDA requirements. By setting higher standards, these companies not only enhance food safety but also build consumer trust. Kroger, for example, has adopted a comprehensive traceability policy covering all food products entering its facilities, not just those mandated by FSMA. This proactive approach allows the retailer to stay ahead of potential regulatory changes and maintain operational efficiency. Catherine Cosby, Kroger’s director of food safety and regulatory compliance, emphasized the importance of anticipating future shifts in traceability requirements. Consumer expectations for transparency further drive these initiatives, as customers increasingly demand insight into the origins of their food products.

Addressing Technical and Operational Challenges

Grocers must navigate varying levels of technical capability among suppliers when implementing traceability systems. Partnerships, such as the collaboration between ReposiTrak and Upshop, offer improved access to supply chain data, aiding grocers in meeting compliance demands. Kroger’s efforts to build a centralized system for collecting supplier information and traceability details highlight the importance of integrating technology solutions. Ensuring consistent information sharing with the FDA remains a critical challenge. Retailers must work closely with regulators to clarify any ambiguities in the rule and align their processes accordingly. Addressing subtle differences in supply chain operations is crucial to avoid misinterpretations and ensure compliance. For instance, handling items with missing case labels during transfers between stores requires clear protocols to maintain traceability integrity.

Fostering Industry-Wide Progress

The evolving landscape of food traceability presents both challenges and opportunities for the grocery industry. As retailers adapt to new regulations, they can leverage these changes to enhance operational efficiency and customer satisfaction. By embracing traceability as a strategic priority, grocers can position themselves as leaders in food safety and transparency. Collaboration with suppliers, technology partners, and regulators will be key to overcoming obstacles and driving industry-wide progress.