Upcoming FDA Guidelines on Food Traceability

By Angie Sabourin, Partner

Updated: December 2025 | 2 min read

On January 20, 2026, FDA regulations mandating new food traceability standards will come into effect.

These standards will enable quicker identification and removal of potentially contaminated food through detailed lot-level tracking and reporting between each major step in the supply chain.

Who is Affected?  

If you are a food producer or wholesale distributor that deals with the following product categories, these regulations may apply to you:

• Cheese
• Eggs
• Fresh produce
• Fish*
• Crustaceans (fresh or frozen)
• Shellfish (fresh or frozen)
• Fresh prepared meals containing any of the above (i.e. salads)

What are the Requirements?   

The FDA will require the creation of a Traceability Plan that will provide a detailed description of how Critical Tracking Events (CTE) and Key Data Elements (KDE) will be tracked and reported.

Critical Tracking Events (CTE) are steps in the supply chain process whereby a defined set of Key Data Elements (KDE) must be tracked. These events include:

• Harvesting
• Cooling
• Initial Packing
• First Land-Based Receiver
• Shipping
• Receiving
• Transformation

Within each event, KDEs must be linked to an assigned traceability lot code which can be used for mandatory reporting to both the FDA and the entity that will execute the subsequent Critical Tracking Event. For each lot and for each event, these elements can include:

• Location description (of the sender and receiver)
• Quantity and unit of measurement for the food
• Date of harvest, cooling, and transformation
• Date of receiving
• And many more

Preparing for Compliance 

For some businesses, the FDA’s new traceability requirements could require an overhaul of supply chain processes, data management, and reporting.

LIDD offers a range of services designed to help your business reach compliance with the upcoming guidelines.

• Traceability Audit & Roadmap: Our team will conduct a systematic audit of your supply chain infrastructure and produce a roadmap detailing the required steps to get compliant with the new regulations.
• Reporting & Data Management: LIDD’s experienced team of data engineers and developers can help your business manage data from multiple sources, and compile it into robust, actionable reports you can rely on.
• Technology Support: The new regulations could require updates to the way your ERP, WMS, or OMS collects and processes data. LIDD will support the development of new customizations that streamline data collection for each critical event.
• Technology Selection & Implementation: The new FDA standards don’t necessitate the implementation of new technologies. However, if your operation does not currently utilize an ERP, WMS, or OMS, LIDD can help to identify if there is a need and lead the selection and implementation process.

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