The US government has updated its FDA food traceability rule under FSMA 204, issuing draft guidance and setting a July 2028 compliance deadline. The changes affect food manufacturers and the packaging companies that supply them, particularly those involved in labelling and batch coding.
The rule forms part of the Food Safety Modernization Act and requires certain foods on the Food Traceability List to be tracked more closely through the supply chain.
Businesses must keep clear records showing where food comes from and where it goes next.
Clearer guidance on how the rule works in practice
The US Food and Drug Administration has published draft questions and answers to explain how the food traceability rule should be applied. The document covers different points in the supply chain, including farms, processors, distributors, retailers and restaurants.
For packaging companies, the main issue is how product batches are identified and tracked. Foods covered by the rule must carry batch or lot codes that link to records showing key details, such as the product description, quantity, supplier and customer. If requested, businesses must provide this information to regulators within 24 hours.
This means packaging formats, printed codes and labels must support accurate batch identification. Errors in coding, relabelling or repacking could create compliance problems if products cannot be traced quickly.
Cottage cheese exemption narrows scope
Regulators have confirmed an exemption for certain Grade “A” cottage cheese products that are already covered by an established dairy safety system. These products will not need to meet the additional traceability record requirements under the rule.
However, companies handling these products must still keep basic records of who supplied the food and who received it.
Packaging suppliers serving dairy producers should check which product lines fall inside or outside the exemption, as requirements may differ.
Industry sessions to address traceability challenges
The agency has also announced regular stakeholder sessions to discuss how the food traceability rule will be implemented. These meetings are intended to gather feedback on practical challenges, including how to track food at batch level and manage records efficiently.
For packaging professionals, the extended timeline to July 2028 offers more time to review coding systems, data management processes and label design.
As food producers strengthen their traceability systems, packaging will play a central role in ensuring that batch information is clear, accurate and easy to retrieve.
