In November 2022, the U.S. Food and Drug Administration (FDA) announced a rule on food traceability. If you haven’t heard about it, that isn’t surprising—most people haven’t. That partly has to do with the quiet, behind-the-scenes way that the federal government often works, and partly to do with the fact that the required rule compliance date set by FDA isn’t until January 20, 2026.

Why would the FDA give everyone more than three years to comply with the rule? Therein lies the story of why most haven’t heard of the rule—and why it’s such a problem.

But before we begin to tell it, it helps to know what the rule does. According to the FDA, anyone that makes, processes, packs, or holds foods on the agency’s Food Traceability List will need to collect and maintain data about those foods. The list includes foods such as “fresh cut fruits and vegetables, shell eggs and nut butters, as well as certain fresh fruits, fresh vegetables, ready-to-eat deli salads, cheeses, and seafood products.” In particular, the data will have to trace the food all the way back through the food supply chain to its origin. The idea is to aid in product recalls and gather the information needed for food safety measures.

However, the level of detail retailers will be required to collect under the rule is staggering. It requires businesses to track foods on the Food Traceability List all the way down to the lot level. That doesn’t mean following it by the truckload or pallet—the FDA wants retailers to know the information on an individual hard-boiled egg that gets chopped and put into a salad. And if asked, the retailer must provide the required data on that hard-boiled egg to the FDA within 24 hours. If you make and sell one salad per week, that might not be a big deal. But in reality, compliance won’t be sustainable for many businesses.

The rest of “Traceability: What You Don’t Know Could Hurt You” can be found in the November 2024 edition of NACS Magazine.