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FSMA Proposes New Rule for Food Traceability

Saro Loucks

Saro Loucks

November 4, 2022

FSMA Proposes New Rule for Food Traceability

There are additional food traceability requirements coming in November 2022. These requirements affect businesses that manufacture, pack, process or hold foods that the FDA has included on the Food Traceability List (FTL). As a business that works with foods on the traceability list, you must maintain records containing Key Data Elements (KDEs) that are associated with Critical Tracking Events (CTEs). food safety software is here to help you meet the improved FSMA standards set by the FDA. Our software tracks supplier inventory does quality batch management and can keep required logs and records such as sanitation and time and temperature. We also offer an Enterprise plan which gives you access to our professional food safety consultants. 

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What Foods Are On the FSMA Food Traceability List?

      • Cheeses other than hard cheeses

      • Chicken eggs

      • Nut butters – not seed or soy butters

      • Cucumbers (fresh) – all varieties

      • Herbs and leafy greens (fresh) – all varieties

      • Melons (fresh) – all varieties

      • Peppers (fresh) – all varieties

      • Sprouts (fresh) – all varieties

      • Tomatoes (fresh) – all varieties

      • Tropical tree fruits – Includes all types of tropical tree fruit, such as mango, papaya, mamey, guava, lychee, jackfruit, starfruit, etc.

      • Fresh cut fruits and vegetables of all types

      • Finfish, including smoked fish – Includes all finfish species, such as cod, Alaskan pollock, tuna, mackerel, grouper, barracuda, salmon, etc.; except does not include siluriformes fish, such as catfish 

      • Crustaceans- includes all crustacean species such as shrimp, lobster, crayfish, crab, etc.

      • Mollusks, bivalves – includes all species such as clams, oysters, mussels, etc, but does not include scallops.

      • Ready-to-eat deli salads – includes all types such as pasta salad, egg salad, pasta salad, but does not include meat salads.

    What are Critical Tracking Events and KDEs?

    Critical tracking events are steps in your procedure that require tracking of KDEs (key data elements such as dates received, where the ingredient is from, etc.)

    Examples of CTEs

    Growing Food

    Sprout growers have additional KDEs to maintain that are specific to sprouts.


    Either the final link in the supply chain (consumer receives) or the “first receiver” is someone that receives a food from a farm to process or package into a product.


    The step at which the food is “created” from a single FTL food WITHOUT adding any other foods on the traceability list. For example, peanut butter is a created food.


    The process of changing an FTL food through its package, label, combining ingredients or processing. Transformation does not include single ingredient packaged foods or creating a food.


    Traceability program records must be kept for any shipping. The software is perfect for this application.

    Other Requirements

    Records must be maintained, legible, and stored properly to prevent loss or destruction.

    The traceability records must be given to the FDA within 24 hours after their request for them.

    You must keep traceability information in an electronic sortable spreadsheet when the FDA requests information during a recall, outbreak, or public health threat.

    Foodready is a food safety software and consulting company. Our software has a HACCP builder, food traceability, you can create your own checklists to manage your HACCP plan or track other items, ingredients, tasks, or events. With our Enterprise program you will have access to food safety quality assurance professionals who can help you with GFSI, SQF, GMP, SOP, BRC, CGMP, HACCP, gap analysis, or prepare for audits like the Costco audit, the Whole Foods audit, Publix audit, Kroger audit, Safeway audit, Meier audit, HEB audit and more.

    In this article

    Saro Loucks

    Saro Loucks

    HACCP Certified, food safety enthusiast.

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