CHICAGO, June 17, 2026 — The food industry has made great strides in preparing for the comprehensive food traceability requirements that take effect July 20, 2028, but significant challenges remain, according to the U.S. Food and Drug Administration.
Its acknowledgement of the complications that persist prompted at least one major food-industry group to press again for postponement of the Food Traceability Rule’s start date.
The agency’s readiness assessment was based on a series of mock food safety situations the FDA posed as tests to 15 food sellers, including two nationwide restaurant chains, a regional multi-unit operation and a small convenience-store brand. The other parties were food retailers of various sorts.
The participants were asked to invite their suppliers and distributors to join the exercise. The results were released to coincide with a June 15 public forum and information-gathering session on the FDA’s Food Traceability Rule.
The FDA commenced the trials by asking participating restaurants and grocers to trace back a product. Consumer-facing businesses were chosen as the starting point because those locations are where most food-poisoning or recall situations begin, the FDA noted. The participants were aware that the situations were drills rather than true crises.
The products designated as the trace-back items differed from participant to participant. Five types of supplies were cited: semi-soft cheese, wild-caught finfish, whole head leafy greens, fresh-cut leafy greens and nut butter.
In keeping with the Food Traceability Rule, participants were expected to provide detailed information about their receipt of a product and its transition to the next link in the supply chain within 24 hours. Most were able to meet that deadline, the FDA said.
It offered special praise for an unnamed restaurant chain and a retailer for shaving time out of the process by reporting where the hypothetical product had been several links higher in the supply chain. They gathered the information from their suppliers through a simple request, cutting 48 to 96 hours from the tracing process.
That and other factors led the FDA to observe in its analysis of the findings that technology mattered less in mapping a product’s farm-to-fork journey than the strength of relationships between various links in the supply chain.
"Technology itself was less determinative of success than whether supply chain partners had agreed on what data to collect, maintain, and share—and how,” the FDA observed.
It noted that the traceability tools used by the participants ranged from ultra-sophisticated tracking technology to printed invoices and receipts.
Where the tracing process broke down was usually in pinpointing the early location of a product headed for a restaurant or supermarket. The FDA cited the example of how an item was traced back to the farm where it was produced. Overlooked was the product’s next stop, a place where the food was kept cool before heading to market.
The Food Traceability Rule is a landmark requirement that’s intended to allow food-safety watchdogs to pinpoint where a product posing a risk is certain to be within the supply chain at any given moment. Because of the complexity involved, adoption has already been delayed to July 20, 2028, from the original scheduled start date of Jan. 20, 2026.
After the FDA’s public forum on June 15, FMI The Food Industry Association issued a statement encouraging the FDA to consider further postponement.
“We welcome FDA’s recognition of the significant implementation challenges that remain,” said FMI Chief Public Policy Officer Jennifer Hatcher. "Extending the compliance deadline is an important step that acknowledges the complexity of implementing the Food Traceability Rule across a highly interconnected food system and provides an opportunity for food companies to identify and implement effective solutions.”
The association also asked the FDA to afford the flexibility some companies will need to comply with the traceability requirements.
The FDA has yet to publicly respond.