Food Traceability Rule to Hit January 2026

The FDA’s Food Traceability Rule hits in January 2026. And a recent report from the Reagan-Udall Foundation found that retailers, suppliers, and distributors have no idea how it works.

Deets: The new rule will require anyone manufacturing, processing, packing, or holding foods on the Food Traceability List “to maintain records containing key data elements associated with specific critical tracking events and provide the information to the FDA within 24 hours.”

There are a lot of moving parts. Companies shipping foods under the ruling would need to provide Traceability Lot Codes (TLCs) for each lot of food. 

Warehouse management systems play a huge role in the process, but can vary greatly. “Most are likely not capable of capturing all [required data points] without significant upgrades or overall system replacement,” the report said.

When it comes to reporting, participants are confused on when they need to submit a spreadsheet template requested by the FDA. If there is a foodborne illness outbreak, there’s more confusion on how the FDA investigates, or what happens if the codes or labels are lost or damaged—as this leads to unreliable reporting.

This is kind of a big deal: Annually, 48M Americans get sick due to foodborne illnesses. In 2022, 419M units of food were recalled, a 700.6% increase from 2021. Traceability and transparency are critical. 

Where this goes: Survey participants said they want more pilots, the ability to share what they’ve learned, and tests for small, medium, and large businesses. They’d also like to explore public-private partnerships with state regulators and public health agencies—and the FDA said it’s willing to make this work.