Food Safety Modernization Act (FSMA) Section 204(d)
Background
The Food Safety and Modernization Act (FSMA), signed into law in 2011, is a comprehensive, far-reaching food safety law that impacts virtually segment of the food supply chain, including distribution. The U.S. Food and Drug Administration (FDA) is the federal regulatory agency that administers and enforces the FSMA.
Section 204(d) of FSMA requires that farmers, manufacturers, food processors, distributors, retailers and restaurants track certain foods as the products move through the food supply chain. The covered foods are considered high-risk for contamination or food-borne illness outbreaks. The data about these subject foods that is required to be tracked includes the manufacturing source of the food, a lot code issued by the manufacturer for each batch of the product produced, a description of the food product including the quantity and the weight, the destination of the food product, receiving and shipping dates, and the temperature of perishable or frozen foods. The original implementation date of FSMA Section 204(d) was January 20, 2026, but the FDA issued an announcement in March 2025 that it intends to extend the implementation date by 30 months.
CDA Webinar Series
"Understanding FSMA Section 204(d) – What It Means for Your Business"
Wednesday, July 23 at 1:00-1:30 PM ET
Join us for the first in a series of exclusive CDA member webinars focused on the Food Safety Modernization Act (FSMA) Section 204(d) – the FDA’s Food Traceability Rule. This initial session will break down what the rule entails, its implications for your business, and how CDA is championing a strategic approach to support members through education, advocacy, and practical resources. Stay ahead of the curve of FSMA 204—don’t miss this essential opportunity to get informed and prepared.
To secure your spot, contact Lauren Herbert for the registration link.
Key Resources
The following resources provide key information, tools, and insights to support compliance with FSMA Section 204(d):
FDA Resources
To assist industry in understanding the requirements of Section 204(d) of FSMA, the FDA has provided a dedicated webpage with numerous resources to assist food supply chain businesses, including distributors, obtain information about the requirements of Section 204(d). This dedicated FDA webpage can be found here:
https://www.fda.gov/food/food-safety-modernization-act-fsma/fsma-final-rule-requirements-additional-traceability-records-certain-foods
On the webpage, there are numerous sections that provide additional information on key topics related to Section 204(d) of FSMA. These sections are as follows:
- Getting Started with the Food Traceability Rule
- Food Traceability List
- Key Features
- Full and Partial Exemptions
- Modified Requirements, Exemptions, and Waivers
- Critical Tracking Events and Key Data Elements
- Supply Chain Examples
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- Traceability Lot Code
- Traceability Plan
- Electronic Sortable Spreadsheet
- Guidance for Industry
- Frequently Asked Questions about the Food Traceability Final Rule
- Stakeholder Calls, Webinars, and Meetings
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Questions? Contact Tom Briant (tomb@cdaweb.net; (703) 208-1641),
Kathee Facchiano (kfacchiano@capitoldecisions.com; (202) 638-1950)
or Sarah Herbert (sherbert@capitoldecisions.com; (202) 638-0326).