The clock is ticking to get FSMA 204 compliant

ATLANTA — With an early 2026 deadline, 2025 is the year that companies across the fresh produce supply chain will need to get serious about FSMA 204 compliance.

FDA’s Food Safety Modernization Act final food traceability rule (FSMA 204) standardizes record-keeping and traceability, and it’s already in effect and will be enforced starting January 20, 2026.

Experts at an IFPA Produce and Floral Show education session gave attendees information on how to become compliant, if they aren’t already.

A key component of FSMA 204 is having Produce Traceability Initiative (PTI) compliant case labeling, and Andy Kennedy, chief traceability officer at iFoodDS, said IFPA estimates that about one-third of fresh produce being shipped is not compliant as of fall 2024.

If your company is not compliant with FSMA 204, Kennedy says the time is now to read and understand the rule; create a traceability plan and begin to execute it; and review and evaluate.

“Then it’s rinse and repeat,” he said.

Angela Fields, senior consumer safety at FDA, confirmed the compliance date and said FDA does not anticipate delaying it, but FDA is still listening to stakeholders.

She also said inspections are not scheduled to begin until January 2027, but companies should not plan on being out of compliance in 2026.

“If you’re involved in an outbreak or health event [after the deadline], you will be held accountable, and we will use our enforcement,” Fields said.

Kennedy used the analogy of waiting to be in compliance until 2027 to renting a car in Europe and not buying insurance and then taking your chances.

He said 2025 is the year to start testing and refining your traceability system.

“Focus on progress, not perfection,” Kennedy said. “But know that this rule will be around for a long time.”

Angela Nardone, COO at Share-ify, said IFPA and FDA have excellent resources on the rule, which you can find here: 

FSMA 204 Resources

FSMA Final Rule on Requirements for Additional Traceability Records for Certain Foods | FDA

Fields said FDA knows compliance will not be easy, but it is the law.

“FDA wants to educate as we regulate,” she said.

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