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.”

For industrial-scale food producers, staying compliant with a patchwork of state, federal, and international regulations is challenging. The State of Alabama requires commercial manufacturing operations like Mar-Jac to maintain National Type Evaluation Program (NTEP) certification on their weighing and measuring instruments. Not only do the scales and other hardware devices themselves need to be certified, but the software reading data from these devices must also conform to the standards of the National Conference on Weights and Measures, ensuring the manufacturer’s data is accurate.

Industrial-scale food producers manage potentially hundreds of individual labels per each product code, item code, SKU, or material items, which creates a headache for version control and maintenance. The complexity of managing so many labels leads to data errors and human errors that negatively affect quality. According to the USDA’s Food Safety and Inspection Service (FSIS) the ten most common labeling mistakes food producers make are: