New FDA traceability requirements are effective January 20, 2023. The FSMA Final Rule: Requirements for Additional Traceability Records for Certain Foods includes a requirement for those who manufacture, process, pack, or hold foods on the Food Traceability List (FTL) to establish and maintain records containing Key Data Elements (KDEs) associated with different Critical Tracking Events (CTEs). The FDA notes that while the proposed requirements only apply to those foods on the FTL, “they were designed to be suitable for all FDA-regulated food products. FDA would encourage the voluntary adoption of these practices industrywide.”

This last year revealed many vulnerabilities and challenges for food suppliers. The pandemic exposed a vulnerability in manufacturers’ reliance on human labor. Regulatory bodies like the FDA, USDA, and GFFA are compelling supply-chain participants to adopt common standards and digital technologies. Retailers – who are under pressure from consumers demanding more variety, sustainability, transparency, and ethical sourcing – are increasingly willing to go around manufacturers to create the products they need if they can’t get the relationship they want with the manufacturer. These challenges will continue beyond 2021.