Traceability Just Got 30 More Months. The Question Is: Will the Data Be Ready?
When the FDA released its updated FAQ for the FSMA 204 Traceability Rule, it wasn’t just another regulatory update. Buried in the details was a big shift: the official proposal to extend compliance to July 2028. Businesses now have 30 more months to prepare— and a 30-day period ending September 8th — to provide feedback. But here’s the truth: additional time alone won’t fix bad data.
FDA Proposes to Extend Compliance Date for Food Traceability Rule and Issues New FAQs and Other Resources
The FAQ offered a few important clarifications. Routine inspections won’t begin until 2027, though for-cause requests can still happen sooner. FDA is building its own Product Tracing System (PTS) to handle outbreak data. And while the agency acknowledged that 100% error-free KDEs aren’t realistic, companies will still be expected to correct errors quickly and put quality checks in place. Even the handling of reference documents is spelled out, aiming to avoid duplication and speed inspections.
These clarifications are welcome, but they shine a light on the bigger issue: data quality and interoperability. Traceability doesn’t break down because technology doesn’t exist. We already have APIs, EPCIS standards, AI to detect anomalies, and cloud platforms that can move data. What breaks down is how the data is collected, formatted, and shared. Too often it’s incomplete, inconsistent, or locked in proprietary systems. That’s not just a compliance problem — it’s a business problem. It erodes consumer trust, slows crisis response, and undermines sustainability commitments.
Compliance requirements provide a floor, not a ceiling. The real opportunity in these 30 months is to use the extra time to build the kind of trust and interoperability that makes traceability valuable for everyone: regulators, businesses, and consumers.
And no single company can solve this alone. Fixing blind spots requires an ecosystem mindset alignment on standards, interoperability across systems, and partnerships that let data move freely without ripping and replacing existing infrastructure. That’s the kind of collaboration we’re leaning into at Starfish: building neutral connections, working with like-minded solution providers, and helping the industry move from isolated compliance projects to a truly connected network.
The FDA has extended the date. The question is no longer if compliance will come — it’s whether the data will be ready.
At Starfish, we believe this is the inflection point. The FDA’s extension is not an excuse to wait, it’s an opportunity to lead. Over the next 30 months, the companies that embrace collaboration, invest in data quality, and connect their systems will set the pace for the industry. They’ll be the ones that turn compliance into resilience, and regulation into trust.
Let’s use this time wisely. Not just to meet the rule, but to build an ecosystem that delivers safer food, stronger trust, and a more connected supply chain.
Johnna Hepner
Johnna Hepner brings over 30 years of experience driving innovation in food safety and supply chain systems. She has held leadership roles at the Produce Marketing Association, Markon Cooperative, and iFoodDS, where she championed initiatives to enhance food safety, improve supply chain transparency, and advance digital adoption in the produce industry.
