For years, food traceability has resembled the Wild West.
Companies throughout the supply chain have long relied on different processes and technologies to track products. When a food safety issue occurs, identifying affected items and removing them from the supply chain can be time-consuming and costly, often leading to broad recalls that impact consumers, brand reputation, and the wider industry.
Today, the Food Safety Modernization Act (FSMA) Rule 204 is the new sheriff in town. Its goal is to bring greater order to a chaotic landscape by establishing new expectations for how items on the Food Traceability List are tracked along the supply chain.
For many organizations, the journey to compliance began with a single question.
What technology do we need to comply?
It’s a reasonable question. But as many companies move from planning to implementation, they are discovering that technology is only one piece of a much larger puzzle.
“This is not about a technology system. It’s more of a business transformation that touches different people, different departments, but also, it’s across supply chain partners,” said Lucelena Angarita, director of supply chain visibility at GS1 US. “It’s a whole change management that needs to happen.”
While it would be convenient if a single technology system led to quick compliance, the organizations that have begun FSMA 204 compliance pilots have found that it calls for evaluating existing processes, coordinating with trade partners, modernizing legacy technologies, improving master data accuracy, adopting common standards, and rethinking how traceability information is captured and shared.
Pilots conducted by Wegmans Food Markets and Sysco each uncovered operational challenges that weren’t fully apparent until they moved beyond planning and began testing their processes.
The takeaway? Companies that begin testing today will have more time to identify gaps, refine processes, and strengthen collaboration before the FSMA 204 compliance deadline arrives on July 20, 2028.
Why testing matters more than planning
Understanding FSMA 204 requirements is one thing. Determining how those requirements affect day-to-day operations is another.
As organizations begin testing their traceability programs, they’re shining a spotlight on how information flows through existing workflows, technologies, and trading partner relationships.
“Whatever you have on paper and whatever processes you think are working, when you look at them in real life, they could be very different,” Angarita said. “The pilots helped identify those gaps.”
And those gaps may extend well beyond technology. Even when companies feel comfortable with their own systems, they need greater visibility into the capabilities and processes their trading partners use. They realize they can’t achieve compliance in a silo because they depend on their supply chain network to capture and share accurate data as well.
When testing happens early, these findings turn into opportunities rather than obstacles. It’s a chance to refine strategies and create more effective systems that work for all partners involved. Organizations that wait will face the same challenges, but with greater pressure, stress, costs, and urgency as the 2028 deadline approaches.
What Wegmans learned by putting traceability to the test
On paper, Wegmans Food Markets’ pilot looked relatively straightforward. The retailer set out to evaluate the traceability of prepared sushi products as they moved through production and distribution.
Individual ingredients arrived from multiple suppliers before being combined into finished products, creating additional transformation events that required documentation as raw ingredients became packaged meals. Actions that seemed simple in theory became more nuanced when evaluated in a live production environment.
The pilot reinforced an important operational reality. Capturing additional traceability data is only valuable if it can be incorporated into existing operations without creating unnecessary disruption.
Referring to the Wegmans experience, Angarita said, “They realized, ‘I’m going to have to do all this in a way that is less disruptive for the system.’”
Wegmans’ biggest lessons came from looking inward — examining its own production processes and workflows. Sysco’s pilot would highlight a different reality: successful traceability also depends on the organizations beyond your own four walls.
What Sysco learned about supply chain readiness
Sysco, a leading foodservice distributor, set out to examine where products move quickly among manufacturers, distributors, and customers.
The pilot reinforced that even the most effective internal processes depend on consistent, accurate information from trading partners. For many organizations, that’s easier said than done.
Suppliers often operate with varying levels of technology. Some exchange information through sophisticated digital systems, while others rely on spreadsheets or other manual processes.
Successfully tracing products across the supply chain requires a way for all of those organizations to communicate consistently, regardless of the platforms they use.
“FSMA 204 says, ‘this is what we need companies to do,’ and then GS1 US has stepped in to help with the how,” Angarita said. “We focused on a common language, not the use of a specific system or technology.”
That common language allows organizations with different levels of digital maturity to exchange traceability information more effectively. Rather than requiring every trading partner to adopt the same software platform, GS1 Standards provide a consistent framework for identifying products, locations, logistics units, and critical tracking events (CTEs), making it easier to capture and share traceability data across the supply chain.
To help smaller growers participate more easily, Angarita said GS1 US is also developing Rapid Record, a mobile tool that allows users to capture and share required FSMA 204 traceability information through simple text messages. It’s designed for organizations with limited technology resources, and it would help them provide consistent, standardized information to trading partners.
As organizations begin engaging their supplier networks, Angarita encourages them to focus first on the relationships that present the greatest operational impact.
“Start with your highest-volume, most-critical trading partners,” she said. “That’s where you’ll get the biggest bang for your buck while testing.”
By strengthening those relationships first, organizations can reduce risk, build momentum, and establish a scalable foundation before expanding their efforts across the rest of the supply chain.
A 5-step framework for getting started
The experiences of early adopters demonstrate that FSMA 204 readiness isn’t achieved through a single project or technology implementation. It’s built over time through careful planning, collaboration, and continuous improvement.
Organizations beginning their own journey can draw on several common lessons that emerged from the Wegmans and Sysco pilots.
Review. Start by evaluating current traceability processes rather than assuming they already align with FSMA 204 requirements. Identify where additional documentation, data capture, or process changes may be needed.
Test. Resist the urge to tackle every product or every trading partner at once. Instead, launch a focused pilot to help teams identify operational gaps and refine workflows before expanding more broadly.
Standardize. Adopt consistent methods for identifying products, locations, and key traceability events. Shared standards make it easier to exchange information across organizations, regardless of the technology each partner uses.
Sponsor. Treat traceability as a cross-functional initiative rather than the responsibility of a single department. Bringing together operations, food safety, supply chain, and IT teams helps ensure that process changes are practical, scalable, and supported across the organization.
Start Early. Above all, don’t wait. While the July 2028 compliance deadline may seem distant, implementing new processes, cleaning up master data, establishing data governance practices, engaging trading partners, and validating traceability programs takes time.
Organizations that begin now will have greater flexibility to refine their approach, while those that delay risk compressing years of organizational change into a much shorter timeline.
“There’s no magic bullet,” she said. “They realize they have to work together to understand their whole supply chain, understand where the breakdowns are, and work together to address them.”
FSMA 204 may be the new sheriff in town, but compliance won’t happen overnight. Organizations that begin testing now will be better positioned to bring greater order, visibility and confidence to their supply chains long before the July 2028 deadline arrives.
