In just over a year, grocers and their suppliers will need to adhere to the Food and Drug Administration’s new food traceability requirements, set to take effect by Jan. 20, 2026. However, significant questions remain regarding compliance challenges, according to a recent report from the Reagan-Udall Foundation for the FDA.

The report, based on industry roundtables held this spring with executives from companies like General Mills, FMI, Subway, and United Natural Foods, Inc., highlights key areas of confusion surrounding the new rule. These include concerns about the level of labeling required for Traceability Lot Codes (TLC), the capabilities of existing warehouse management systems, and reporting metrics.

Participants expressed uncertainty about the specifics of labeling and tracing activities, the ability of warehouse management systems to capture required data points, and the submission of completed spreadsheet templates to the FDA. Additionally, questions were raised about the FDA investigation process in the event of food-borne illness outbreaks.

Moving forward, industry pilot programs have been testing current systems with a focus on one food product or category. Participants are calling for more pilots, templates for running pilots, and public-private partnerships to support implementation, ensure data consistency, and share learnings with the FDA.

While the feasibility of these proposals remains uncertain, some participants have suggested staggering the rule’s compliance date by sector or company size to facilitate a smoother transition to the new requirements.


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