FDA Updates Food Traceability FAQ and Makes Technical Corrections

On September 28^th, the Food and Drug Administration (FDA) updated its Food Traceability FAQ to provide additional information about the FDA’s Product Tracing System and explain how the agency intends to conduct initial inspections beginning in 2027.

The Food Traceability Final Rule was published in November 2022, establishing traceability recordkeeping requirements, beyond those in previously existing regulations, for persons who manufacture, process, pack, or hold foods included on the Food Traceability List (FTL). The new program was designed to facilitate faster identification and rapid removal of potentially contaminated food from the market, resulting in fewer foodborne illnesses and/or deaths.

FDA set January 20, 2026 as the compliance date to give those subject to the rule time to come into compliance. FDA has indicated that it plans to take an “educate while it regulates” approach to support widespread, successful compliance as was done for other FDA Food Safety Modernization Act (FSMA) rules.  Additionally, the FDA does not intend to begin routine inspections until 2027.  During this time, the FDA will be working with regulatory and other partners to advance training and other educational opportunities.

In addition, FDA has published some published technical amendments to the Food Traceability final rule. The agency explained that the final rule contained some editorial and inadvertent errors in the preamble and one of the codified provisions. To correct these errors, four changes have been made:

• Correction of a cross-reference that pointed to the wrong numbered response,
• Addition of a grammatical article,
• Deletion of an inaccurate sentence,
• Addition of parenthetical language.