FSMA 204: Understanding the FDA’s New Food Traceability Rule

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Published on
February 7, 2025

The Food Safety Modernization Act (FSMA) 204, officially titled the Final Food Traceability Rule, is a regulation introduced by the U.S. Food and Drug Administration (FDA) to enhance food safety through improved traceability. The rule aims to ensure rapid identification and response to foodborne illnesses and contamination events by establishing strict record-keeping and data-sharing requirements for certain high-risk foods.

1. What is FSMA 204?

The FSMA 204 Final Rule is part of the FDA’s Food Safety Modernization Act (FSMA) and focuses on:

  • Strengthening traceability across the food supply chain.
  • Reducing foodborne illnesses by enabling faster recalls.
  • Ensuring real-time access to traceability data for compliance and safety.

This rule applies to specific foods listed in the Food Traceability List (FTL) and requires businesses to maintain and share key data elements (KDEs) and critical tracking events (CTEs) for these foods.2. What is the Food Traceability List (FTL)?The FTL is a list of foods that are considered high-risk for contamination and require stricter traceability. The foods on this list include:

  • Fresh produce (leafy greens, tomatoes, cucumbers)
  • Fresh herbs (cilantro, parsley, basil)
  • Shell eggs
  • Cheese (soft cheeses like brie, feta)
  • Nut butters (peanut butter, almond butter)
  • Certain seafood (tuna, crustaceans, smoked fish)

Any business that manufactures, processes, packs, or holds these foods must comply with FSMA 204’s record-keeping and reporting requirements.3. Key Components of FSMA 204To ensure compliance, businesses must track Critical Tracking Events (CTEs) and record Key Data Elements (KDEs) throughout the supply chain.A. Critical Tracking Events (CTEs)These are points in the supply chain where food moves or undergoes transformation. FSMA 204 requires businesses to track:

  1. Growing – Where and how the food was grown.
  2. Receiving – When food enters a facility or is received by a buyer.
  3. Transforming – Any processing, cooking, or repackaging of food.
  4. Shipping – When food is transported to another entity.
  5. Retail/Consumption – The final step before the food reaches consumers.

B. Key Data Elements (KDEs)At each CTE, businesses must record and maintain specific data to ensure full traceability. Some examples include:

  • Lot numbers
  • Harvest locations
  • Time and date of shipment
  • Temperature control logs (for perishable items)
  • Supplier and distributor information

4. Why is FSMA 204 Important?A. Faster Response to Foodborne Illness Outbreaks

  • With real-time tracking and standardized records, businesses and regulators can quickly identify contaminated products and prevent outbreaks from spreading.

B. Improved Consumer Safety

  • Enhanced traceability reduces the risk of foodborne diseases, protecting public health.

C. Stronger Supply Chain Transparency

  • Companies will have better visibility into their food sources, reducing fraud and ensuring compliance.

D. Compliance with Regulatory Requirements

  • Businesses that fail to comply with FSMA 204 risk fines, penalties, and recalls, leading to financial and reputational damage.

5. Who Needs to Comply with FSMA 204?A. Businesses AffectedThe rule applies to all entities in the food supply chain, including:

  • Farmers and growers
  • Food processors and manufacturers
  • Distributors and wholesalers
  • Retailers and grocery stores
  • Foodservice establishments (restaurants, cafeterias, etc.)

B. Who is Exempt?Some businesses are partially or fully exempt, such as:

  • Small farms (with annual sales below a certain threshold).
  • Certain restaurants and foodservice providers (if they sell directly to consumers).
  • Farms selling food directly to consumers.

6. How to Achieve FSMA 204 Compliance?To meet FSMA 204 requirements, businesses should:

  1. Implement a digital traceability system to track CTEs and KDEs.
  2. Adopt blockchain or cloud-based solutions to store real-time records securely.
  3. Train employees on FSMA 204 compliance and data management.
  4. Work with suppliers and partners to ensure all traceability data is shared accurately.
  5. Regularly audit traceability records to stay prepared for FDA inspections.

7. How Spydra Can Help with FSMA 204 ComplianceSpydra is a blockchain-powered traceability platform that helps businesses comply with FSMA 204 by:

  • Automating traceability workflows to ensure accurate and real-time data tracking.
  • Integrating with existing supply chain systems, reducing manual record-keeping errors.
  • Providing a secure, decentralized ledger for all food traceability records.
  • Ensuring real-time data sharing among stakeholders for faster response to food safety issues.

With Spydra's blockchain-based solution, businesses can seamlessly meet FSMA 204 requirements, reduce operational risks, and enhance consumer trust.Case Study: GS1 Maahi Ghee Traceability with SpydraThe GS1 Maahi Ghee Traceability Project showcases how Spydra’s blockchain technology is used to enhance transparency in the dairy supply chain.Project Highlights

  • Implemented in Junagadh, Gujarat, involving 10,000+ farmers.
  • Tracks cattle health, milk collection, processing, and ghee production.
  • Uses Hyperledger Fabric Blockchain to create an immutable, real-time traceability system.

Technology Implementation

  • Asset Tokenization: Digitally represents food items for seamless tracking.
  • API Integration with SAP & NDLM: Automates data capture from existing enterprise systems.
  • GraphQL & REST API: Enables real-time traceability reporting.

Impact & Benefits

  • Ensures FSMA 204 compliance through comprehensive traceability.
  • Reduces fraud and counterfeiting by providing verifiable data.
  • Improves consumer trust with transparent food origin tracking.

Conclusion: The Future of Food Traceability with SpydraThe food industry must embrace digital transformation to meet FSMA 204 compliance requirements and enhance food safety. Traditional traceability methods are slow and error-prone, making them inadequate for modern supply chains.Spydra’s blockchain-based solution offers:

  • Real-time tracking
  • Automated and immutable record-keeping
  • Seamless compliance with FSMA 204
  • Cost-effective scalability for all businesses

By integrating blockchain technology, companies can strengthen supply chain transparency, reduce recalls, and improve public health outcomes.Act Now!With FSMA 204 compliance deadlines approaching, businesses should start integrating blockchain solutions like Spydra today to ensure a safer and more transparent food supply chain.

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