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FSMA 204 Food Traceability Rule Training: FSPCA Curriculum, Live Online

A 1.5-day live course on Zoom built on the FSPCA Food Traceability Rule curriculum. Learn which of your foods are covered, map your Critical Tracking Events and Key Data Elements, draft a traceability plan, and leave with a working to-do list for your facility.

  • FSPCA FTR Curriculum
  • 1.5 Days on Zoom
  • 21 CFR Part 1, Subpart S
  • FSPCA Certificate Included

Last updated October 8, 2026

Live online · Instructor-led

Enroll in FSMA 204 Training

$699 per seat

Next class
Enroll Now — $699
  • 1.5 days, live with an FSPCA Lead Instructor
  • FSPCA participant manual, exercises and appendices
  • Exercises built around your own supply chain
  • FSPCA Certificate of Successful Completion

Secure online checkout. Can't attend? Transfer to the next available class, or request a refund up to 5 days before the course starts.

Training 6+ people? Ask about private training.

What Is FSMA 204 Food Traceability Rule Training?

This live virtual course delivers the FSPCA Food Traceability Rule participant curriculum, the industry training FDA and FSPCA developed for companies that manufacture, process, pack or hold foods on the Food Traceability List. An FSPCA Lead Instructor takes you through the rule chapter by chapter, with exercises built around your own supply chain.

Tuition includes the FSPCA participant manual, exercises and appendices. Attend the full course and take part in the exercises to receive the FSPCA Certificate of Successful Completion.

Enforcement starts no earlier than July 20, 2028.

The original compliance date was January 20, 2026. Congress has since directed FDA not to enforce the rule before July 20, 2028, and FDA has said it will follow that directive. Building CTE and KDE records across a supply chain takes time, so most companies are using the runway now.

  • 1.5 Days

    May 10–11, 2027: Day 1 8:30 AM–4:30 PM CT, Day 2 8:30 AM–12:30 PM CT.

  • Live on Zoom

    Instructor-led and interactive. Sessions aren't recorded, so you attend the whole course live.

  • FSPCA Curriculum

    The Food Traceability Rule participant course FSPCA developed in partnership with FDA.

  • FSPCA Certificate

    The FSPCA Certificate of Successful Completion for participants who attend the full course and take part in the exercises.

Upcoming Dates & Pricing

Live online FSMA 204 training is $699 per seat, including the FSPCA participant manual. The next class is May 10–11, 2027 on Zoom.

Live online

FSMA 204 Food Traceability Rule Training

The FSPCA Food Traceability Rule participant course, live on Zoom over 1.5 days.

FSPCA curriculum · Day 1 8:30 AM–4:30 PM · Day 2 8:30 AM–12:30 PM CT

Upcoming dates$699 per seat

What Is the FSMA 204 Food Traceability Rule?

Section 204 of the FDA Food Safety Modernization Act directed FDA to set additional traceability recordkeeping requirements for higher-risk foods. The result is the Food Traceability Rule (21 CFR Part 1, Subpart S), published November 21, 2022. It applies to anyone who manufactures, processes, packs, or holds a food on FDA's Food Traceability List.

The goal is speed. When an outbreak or recall hits, FDA wants to trace a food through the supply chain in hours, not weeks, so contaminated product comes off the market faster.

  • Record KDEs at Every CTE

    Keep the Key Data Elements tied to each Critical Tracking Event you perform, from harvesting and cooling through shipping, receiving, and transformation.

  • Assign Traceability Lot Codes

    Assign a traceability lot code when you initially pack a raw agricultural commodity, do first land-based receiving of seafood, or transform a food.

  • Keep a Traceability Plan

    Document how you keep records, identify foods on the list, assign lot codes, and who the point of contact is. Farms add a farm map.

  • Produce Records in 24 Hours

    Make records available to FDA within 24 hours of a request, and in an electronic sortable spreadsheet during an outbreak, recall, or other threat.

Source: 21 CFR Part 1, Subpart S (sections 1.1300 to 1.1465).

Is Your Food on the Food Traceability List?

The rule covers the foods on FDA's Food Traceability List, plus foods that contain a listed food as an ingredient, as long as that ingredient stays in the same form it's listed in (for example, fresh).

  • Food Traceability List

    Produce, Eggs, Cheese and Nut Butters

    • Cheeses, other than hard cheeses
    • Shell eggs
    • Nut butters
    • Fresh cucumbers, herbs, melons, peppers, sprouts, tomatoes and tropical tree fruits
    • Fresh and fresh-cut leafy greens
    • Fresh-cut fruits and vegetables
  • Food Traceability List

    Seafood and Deli Salads

    • Finfish, including smoked finfish
    • Crustaceans
    • Molluscan shellfish (bivalves)
    • Refrigerated ready-to-eat deli salads

Some operations are exempt or partially exempt, including small produce farms and small retail food establishments and restaurants (21 CFR 1.1305). The course walks through how to work out whether, and how, the rule applies to you. See FDA's Food Traceability List.

Who Should Attend FSMA 204 Training?

Anyone who builds or runs traceability records for foods on the Food Traceability List.

  • Manufacturers and Processors

    Transformation

    Sites that transform listed foods and assign new traceability lot codes.

  • Growers and Packers

    Farm to pack

    Farms and packinghouses that harvest, cool or initially pack listed produce.

  • Distributors and Warehouses

    Shipping and receiving

    Operations that ship and receive listed foods and keep those KDEs.

  • Seafood Companies

    Seafood

    First land-based receivers and handlers of finfish, crustaceans and shellfish.

  • Food Safety and Quality Staff

    Program owners

    The people who own the traceability plan and the 24-hour records response.

  • Supply Chain and IT Teams

    Systems

    Teams that set up the systems and trading-partner data flows the rule depends on.

Course Curriculum & Agenda

The FSPCA Food Traceability Rule curriculum, chapter by chapter, with exercises throughout.

  • Day 1 · 8:30 AM–4:30 PM CT

    Foundations of the Food Traceability Rule (Chapters 0–3)

    Get oriented to the rule, work out who is covered and what's on the Food Traceability List, then spend the afternoon on the heart of the FTR: Critical Tracking Events and Key Data Elements.

    • Preface: course overview and how the FSPCA course is structured
    • Chapter 1: Introduction and background — why traceability matters and where the FTR came from
    • Chapter 2: Application of the rule — the Food Traceability List, coverage, and exemptions
    • Chapter 3: Critical Tracking Events and Key Data Elements, with annotation exercises
  • Day 2 · 8:30 AM–12:30 PM CT

    Traceability Plan, Recordkeeping & Implementation (Chapters 4–6)

    Turn the rule into a system: build the traceability plan, work through record format and FDA access requirements, and finish with implementation guidance and a to-do list for your facility.

    • Chapter 4: Traceability plan requirements, with drafting exercises
    • Chapter 5: Recordkeeping — format, retention, and the 24-hour electronic sortable spreadsheet
    • Chapter 6: Implementing food traceability programs and procedures
    • Final activity: your FTR to-do list, plus a walkthrough of the appendices

Course Details

Everything you need to know before you enroll.

  • Live online

    Format

    Live, instructor-led training on Zoom with exercises. Sessions aren't recorded, and participants may not record them.

  • 1.5 days

    Schedule

    May 10–11, 2027: Day 1 8:30 AM–4:30 PM CT, Day 2 8:30 AM–12:30 PM CT.

  • $699

    Price

    Per seat, including the FSPCA participant manual, exercises and appendices.

  • Camera & mic

    What You Need

    A computer with a stable internet connection, a webcam and a microphone.

  • FSPCA

    Certificate

    The FSPCA Certificate of Successful Completion, for attending the full course and taking part in the exercises.

  • 5 days

    Changes

    Transfer to the next available class, or request a refund up to 5 days before the course starts.

  • 6+ people

    Groups

    Private on-site or virtual training for 6+ people, on a schedule that fits your team.

Your Instructor

Harmeet brings nearly two decades of food safety consulting and training experience to every class. She has worked with companies ranging from small startups to multinational corporations, helping them navigate regulatory compliance, quality systems and audit readiness.

She combines deep technical knowledge with practical, real-world insight, from FDA Food Safety Plans and supplier programs to recordkeeping systems and staff training.

  • Harmeet Kaur, Director of Training & Consulting Services at Kiwa ASI

    Harmeet Kaur

    Director of Training & Consulting Services, Kiwa ASI

    FSPCA Lead Instructor · SQFI Certified Trainer & Consultant · HACCP Specialist

More FSMA Training

Round out your team's FSMA skills with Kiwa ASI.

PCQI

PCQI Certification Training

The FSPCA Preventive Controls for Human Food V2.0 course. Many teams pair it with FSMA 204 so the people who own the food safety plan also own traceability.

FSPCA V2.0 · 5 half-days · Live via Zoom · 8:30 AM–12:30 PM CT

Upcoming dates$899 per seat
FSPCA · Importers

FSPCA FSVP Training

The FSPCA Foreign Supplier Verification Programs course for U.S. food importers, live online.

Live virtual · instructor-led

Upcoming dates$795 per seat

Dates on request. Ask about upcoming dates

Why Train With Kiwa ASI?

The FSPCA Food Traceability Rule curriculum, taught live online.

  • Official

    FSPCA Curriculum

    The Food Traceability Rule participant course FSPCA developed in partnership with FDA.

  • Practical

    Built Around Your Supply Chain

    Exercises use your own foods, CTEs and trading partners, so you leave with a working to-do list.

  • Format

    Live and Interactive

    Ask about your own operation in real time, not after the fact.

  • Training

    One Team for FSMA

    PCQI, FSVP, food defense and traceability courses from the same training team.

  • Integrity

    Kept Separate From Certification

    Training is delivered by ASI Training and Consulting, LLC, separately from our accredited certification body, ASI Food Safety, LLC. Taking it has no bearing on any audit outcome.

Frequently Asked Questions About FSMA 204 Training

What is FSMA 204?

FSMA 204 is section 204 of the FDA Food Safety Modernization Act, which directed FDA to create additional traceability recordkeeping requirements for high-risk foods. FDA did that with the Food Traceability Rule, formally "Requirements for Additional Traceability Records for Certain Foods" (21 CFR Part 1, Subpart S), published November 21, 2022.

When do companies have to comply with the Food Traceability Rule?

The original compliance date was January 20, 2026. FDA then proposed a 30-month extension, and in November 2025 Congress directed FDA not to enforce the rule before July 20, 2028. FDA has said it will comply with that directive. Building CTE and KDE records across a supply chain takes time, so most companies are using the extra runway to get their systems and trading partners ready.

Which foods are on the Food Traceability List?

The Food Traceability List covers cheeses other than hard cheeses, shell eggs, nut butters, fresh cucumbers, fresh herbs, fresh and fresh-cut leafy greens, fresh melons, fresh peppers, fresh sprouts, fresh tomatoes, fresh tropical tree fruits, fresh-cut fruits and vegetables, finfish (including smoked finfish), crustaceans, molluscan shellfish, and refrigerated ready-to-eat deli salads.

Does the rule cover foods made with ingredients on the list?

Yes, when the listed food stays in the same form it appears on the list. For example, a salad kit containing fresh-cut leafy greens is covered. Once a listed food is changed so it's no longer in its listed form, for example cooked or frozen, the rule generally stops applying downstream, although the company that makes that change still keeps records of receiving the food.

What are Critical Tracking Events (CTEs)?

CTEs are the supply-chain events that trigger recordkeeping under the rule: harvesting, cooling (before initial packing), initial packing of a raw agricultural commodity, first land-based receiving of seafood from a fishing vessel, shipping, receiving, and transformation. Which records you keep depends on which of these events you perform.

What are Key Data Elements (KDEs) and traceability lot codes?

Key Data Elements are the pieces of information you must record for each CTE, such as the traceability lot code, quantity and unit of measure, product description, locations, and dates. A traceability lot code is the identifier that follows a lot through the supply chain. You assign one when you initially pack a raw agricultural commodity, do first land-based receiving of seafood, or transform a food, and you don't create new ones at other steps such as shipping.

What must a traceability plan include?

Under 21 CFR 1.1315, your traceability plan must describe how you maintain your traceability records (including their format and location), how you identify foods on the Food Traceability List, and how you assign traceability lot codes. It must also name a point of contact. Farms that grow or raise a listed food (other than eggs) must add a farm map with geographic coordinates for each field or growing area.

How quickly must records be provided to FDA?

Within 24 hours of a request, or within a longer time FDA agrees to. When FDA is responding to an outbreak, a recall, or another threat to public health, most covered entities must provide the requested information as an electronic sortable spreadsheet, also within 24 hours.

How long must traceability records be kept?

Two years from the date you created or obtained them. Records can be paper or electronic, or true copies of either. When you update your traceability plan, keep the previous version for two years.

Who is exempt from the Food Traceability Rule?

The rule has a range of full and partial exemptions. Examples include small produce farms and other small producers averaging no more than $25,000 a year in sales, shell egg producers with fewer than 3,000 laying hens, retail food establishments and restaurants averaging no more than $250,000 a year in food sales, farm-to-consumer direct sales, and foods that receive a kill step or certain commercial processing. The full list is in 21 CFR 1.1305, and Chapter 2 of the course walks through it.

Is FSMA 204 training required?

No. FDA has stated that training is not a requirement of the Food Traceability Rule. FDA encourages it, though, because it helps companies understand their obligations. This course is a structured way to learn the rule and start building your traceability plan and records.

Who developed this course? Is it FDA-approved?

The Food Traceability Rule participant course was developed by the Food Safety Preventive Controls Alliance (FSPCA) in partnership with FDA, which announced its availability in May 2026 as core, industry-oriented training on the rule. Completing it gives you a working understanding of the FTR. It is not an FDA-approved or FDA-issued certification.

Is this a certification course?

No. FSPCA participant courses are not certification courses, and FSPCA does not certify individuals. Participants who attend the full course and actively take part in the exercises receive an FSPCA Certificate of Successful Completion.

How long is the course, and is it live?

Yes, it's fully live and instructor-led on Zoom. The course runs 1.5 days: Day 1 8:30 AM–4:30 PM CT and Day 2 8:30 AM–12:30 PM CT. You'll need a computer with a stable internet connection, a webcam and a microphone.

When is the next FSMA 204 class?

May 10–11, 2027 on Zoom: Day 1 8:30 AM–4:30 PM CT, Day 2 8:30 AM–12:30 PM CT. Enroll with the enroll box at the top of this page, or email US.Info@kiwa-asi.com or call 1 (800) 477-0778 with questions.

Is the session recorded?

No. Sessions are delivered live and are not recorded, and participants may not record them. To receive the FSPCA Certificate of Successful Completion, you must be present for the entire course and actively take part in the exercises.

What's the refund and cancellation policy?

If you can't attend, email US.Info@kiwa-asi.com or call 1 (800) 477-0778 as soon as possible. You may transfer to the next available class or request a refund up to 5 days before the course start date.

Can you deliver this on-site for our team?

Yes. For groups of six or more, we offer private delivery on site or virtually, on a schedule that fits your team. Many teams pair it with PCQI training so the people who own the food safety plan also own traceability. Email US.Info@kiwa-asi.com or call 1 (800) 477-0778 for a quote.

Ready to build your traceability plan?

Enroll in the May 10–11 live online class, or train 6+ people with private on-site or virtual FSMA 204 training on a schedule that fits your team.

Training & Trust

Kiwa ASI teaches the FSPCA Food Traceability Rule participant curriculum. Training is delivered by ASI Training and Consulting, LLC, separately from our accredited certification body, ASI Food Safety, LLC, to safeguard against conflicts of interest. For private training, email US.Info@kiwa-asi.com.