FSMA 204 Food Traceability Rule Training
Live With an FSPCA Lead Instructor

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.

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.

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.

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.

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.

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.

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.

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.

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.

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.

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.

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.

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.

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

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.

If you can't attend, contact us at US.Info@kiwa-asi.com or 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.

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 for a quote.