FoodĀ Distributors
Is Your Business Ready for FSMA 204, The Food Traceability Rule?
FSMA 204, aka The Food Traceability Rule, sets additional food traceability recordkeeping responsibilities for businesses who manufacture, process, pack, or hold specific ‘high-risk’ foods that are named on FDA’s Food Traceability List. These traceability requirements are being introduced to allow for rapid identification and removal of contaminated foods.
Playing a crucial role in the transportation of food, food distributors who handle foods included on the Food Traceability List must take proactive measures to comply before July 20th, 2028.
Critical Tracking Events (CTEs): Businesses impacted by FSMA 204 need to monitor activities at certain points throughout the food supply chain, where foods are handled, moved, transformed, and may be at risk of contamination. The FDA has listed 7 CTEs in total. This includes harvesting, cooling, initial packing, first land-based receiver, shipping, receiving, and transformation.
Key Data Elements (KDEs): Organizations are required to keep a record of specific traceability data (i.e. KDEs) related to the associated critical tracking events. The data you need to provide will vary depending on the activity.Ā

Understanding The Impact of
FSMA 204 on Food Distributors
Central to increasing food safety and transparency throughout the supply chain is the need to monitor foods in transit. Distributors must maintain, receive and provide accurate traceability data related to two Critical Tracking Events in particular: Shipping and Receiving.Ā
Food distributors take in raw food products from growers and small producers but also work with food manufacturers, shippers, packers, and foodservice businesses, so collaboration is crucial.Ā
Key Responsibilities and Recordkeeping Requirements
While food distributors are responsible for shipping and receiving, they may also be responsible for initial packaging and cooling, depending on the food product they are handling and the form in which they received it from the growers, packers and shippers.
If the growers, packagers and shippers they work with are exempt from the Food Traceability Rule, distributors may also be required to assign initial Traceability Lot Codes.

Download Your Free 7-Step FSMA 204 Compliance Checklist
Prepare your business for the Food Traceability Rule by downloading our free 7-Step Compliance Checklist.
