Starting in 2026, you may need to follow new traceability rules for the foods you process. These rules apply to any manufacturer who works with foods like fresh produce and fish. Look at the FDA’s Food Traceability List for the complete list of foods affected by these rules. The purpose behind this change is to help the FDA identify foods faster during recalls and foodborne outbreaks.
Critical Tracking Events
If you work with foods on the FTL, you must capture specific information when the food on the lists goes through certain points in the production process. The FDA calls these points “Critical Tracking Events,” and they include harvesting, cooling, initial packing, first receiving from a fishing vessel, receiving, transforming, and shipping. A specific lot code must be kept on file for each manufacturer involved in any of these steps. To keep track of the food from the start of the process and lot code must be applied and kept from start to finish no matter how many hands the product passes through.
Traceability Lot Code
The initial point at which food becomes part of the FTL is when this lot code is created. This code must be recorded and remain with the food throughout processing. By using the same lot code, it is much faster for the FDA to find exactly where the food has been.
An example of a food being transformed from a product not on the FTL to being on it The lot code must be created when the food is transformed and is covered by the FTL. For example, you must create a new lot code if you take whole tomatoes and then chop them up and combine them with other ingredients to make ready-to-eat salad bags. Cutting the tomato and having the end product also be on the list means that the lot code will continue with the new product.
You must also have a detailed plan to keep track of this information. The plan must include how you maintain your records over time, including the types of foods you work with and corresponding lot codes.
If the FDA reviews records during a recall or foodborne illness outbreak, they will ask to see your traceability plan.
The FDA recommends keeping electronic records to make it easier to access them quickly. If they request records from you, they will expect to see them within 24 hours. One easy solution is to use the Document Compliance Network to maintain your records. You can store all your records in one place and access them with just a few clicks. Document Compliance Network makes it fast and easy to share requested documentation in a few minutes.
These new traceability rules go into full effect on January 20th, 2026. Make sure you are ready by creating your traceability plan and implementing procedures to keep your records up to date. Don’t wait until the last minute to get your documents in order!