The United States’ Food and Drug Administration’s (FDA) Food Safety Modernization Act (FSMA) represents the agency’s efforts to update the country’s food safety system by shifting the focus from responding to foodborne illness outbreaks to preventing them. Section 204— also known as the Food Traceability Rule— requires the FDA to identify high-risk foods requiring additional records and to establish the relevant requirements.
The objective is to accelerate the identification and removal of potentially contaminated food from the marketplace to reduce foodborne illnesses and deaths. Radio frequency identification (RFID) technologies make it easier.
Decision-makers in the food industry and other affected sectors should know that the FDA has proposed a 30-month extension for parties subject to Section 204’s compliance requirements. Although the initial deadline was January 20, 2026, a 30-month extension changes it to July 20, 2028.
Become Familiar With the Food Traceability List
Although affected parties may breathe a sigh of relief at the extra time, they should use it to refine their RFID strategies rather than halting their efforts and focusing on other matters. Which steps should they take?
The FDA’s Food Traceability List confirms which products require additional recordkeeping practices. Some of the items include cheese, nut butters and fresh cucumbers, indicating a wide assortment of applicable items.
Importance of Ingredients List
A key point is that consumables containing the listed items as ingredients fall under Section 204 if they are in the same format as the named food. Understanding the list’s contents is an excellent starting point for people planning compliance with FSMA 204 and RFID technology requirements.
Decision-makers should review the foods they handle now. They should also assess expansion plans, since companies not initially subject to FSMA 204 must eventually comply with it. Some leaders may also determine that it makes the best business sense to get into compliance now to future-proof their companies.
They could take preliminary steps by implementing robust tracking measures for foods, even if they do not appear on the FDA’s list.
Connect With Supply Chain Partners
The additional traceability measures for Section 204’s foods apply to entities that manufacture, process, hold or pack the products. Those parties must maintain records that have key data elements associated with specific critical tracking events. They are required to give that information to the FDA within 24 hours, or within another reasonable time frame approved by the agency.
That relatively small window emphasizes why those subject to Section 204 should not merely assume that others within their product’s supply chain are taking the necessary steps to become compliant. Now is an excellent time to contact representatives directly to verify this.
Thoughtfully implemented RFID technologies can help leaders capture the required data, but they cannot close compliance gaps caused by poor preparedness. Taking proactive steps is one of the most effective ways to ensure that supply chain partners are ready before the new compliance deadline.
All involved parties can use the extension to discuss challenges they have encountered and how technology may address them. They could also spend the time conducting small-scale trials. Those real-world trials can give leaders the confidence to scale up their investments once they see the payoffs.
Assess the Expected Operational Conditions
RFID technologies assist users by verifying real-time data, including for products in transit. Leaders also use them in conjunction with other options, such as Internet of Things sensors and data analysis platforms. Many food products travel across countries and continents via various transportation methods. Therefore, parties purchasing mobile electronics to strengthen their supply chains and prepare for the FSMA should anticipate the most common environmental challenges that the products may encounter during typical journeys and select suitable options.
Many electronics feature hydrophobic laminates that protect against environmental contaminants and damage. The selected solutions provide safeguards against risks such as ultraviolet rays, moisture, extreme temperatures and dust, depending on the chosen material.
Leaders purchasing RFID solutions to comply with FSMA 204 should have detailed discussions with vendors to explain the environmental factors the products must withstand. Being transparent about those needs from the start enables salespeople to recommend the most appropriate products that can handle those conditions and bring consistently satisfying results.
Set Goals Related to FSMA 204 and RFID Technology
The FSMA delay provides leaders with viable opportunities to create measurable goals related to how an organization will utilize RFID products to fulfill its obligations. Decision-makers can start by thinking broadly about the advantages they would like to harness before narrowing them down into more specific plans and milestones.
For example, research shows that RFID usage in early logistics stages can minimize inventory errors by offering real-time visibility of stock levels. However, companies embracing this approach should discuss their aspirations with other supply chain members. This way, they can ensure that these entities have the necessary technological capabilities to maintain accurate information themselves as well.
Those overseeing technological integrations related to the FSMA should also allow plenty of time for stakeholder feedback, employee training and unforeseen hiccups. Careful planning and phased rollouts contribute to smooth transitions and long-term success.
Case Study: Chipotle
Learning about the initiatives taken by well-known brands to enhance food traceability with RFID is also helpful, as it inspires people about the possibilities. Chipotle, the multibillion-dollar Mexican chain, has implemented RFID-enabled traceability across thousands of locations. This provides the brand with genuine end-to-end supply chain visibility that informs its inventory and replenishment strategy.
Supplier collaboration was a key component of the brand’s plans, as it invited partners to participate in early testing and provided them with an RFID playbook that included best practices and outlined program benefits. Among the participants are five entities that provide dairy products and avocados to Chipotle.
Ingredients arriving at Chipotle locations are labeled with RFID-enabled case labels, which staff scan with readers. Because they work together with existing scanners, each restaurant can roll out the upgrades with minimal investment.
According to the company’s chief operating officer, this approach simultaneously improves experiences for restaurant workers and supply chain partners. The brand can also respond rapidly to any concerns because of these traceability improvements. A similar strategy could help leaders who want to prepare for the FSMA 204 deadline.
Decision-makers may feel tempted to temporarily shift their focus from FSMA compliance due to the extended timeline. However, they should use this extra time wisely by using these suggestions to optimize the overall outcomes while maintaining motivation throughout the organization.
