The U.S. Food and Drug Administration has released a report on a series of traceability readiness tabletop exercises held with industry between March 9 and April 1, 2026. The exercises were designed to help the food industry prepare to comply with the Food Traceability Rule (FTR). The Agency has also released updated Frequently Asked Questions to provide clarity on a number of topic related to the rule.
The FTR —established under Section 204 of the FDA Food Safety Modernization Act —requires covered entities that manufacture, process, pack, or hold foods on the FDA Food Traceability List to maintain additional records that allow FDA to more rapidly and accurately trace food through the supply chain. As part of the tabletop exercises, the FDA worked with industry participants to simulate an FTR records request from FDA. The exercises tested whether participants could locate traceability records associated with the handling of a specific product during a short, defined date range, and provide the information from those records in an electronic sortable spreadsheet within 24 hours, which is consistent with the requirements of the FTR.
The exercises demonstrated that meaningful progress is being made toward meeting the FTR requirements. Most firms responded within 24 hours, and proactive supply chain coordination—more than any particular technology—drove the strongest results. These results are encouraging overall, even though the exercises also demonstrated that some challenges remain with certain data elements. Understanding firm readiness will help both the FDA and industry further prepare for compliance.
The FDA will use the findings of these exercises to inform its ongoing outreach, education, and technical assistance efforts. These exercises, coupled with ongoing engagements, will also help inform potential flexibilities regarding the lot-level tracking requirements in the FTR. The FDA recently issued a discussion paper on this topic and is looking forward to hearing more from interested stakeholders at the public meeting on June 15th and through feedback that can be submitted to a docket as described in the discussion paper.
Additionally, to further support implementation of the rule’s requirements, the FDA has updated its frequently asked questions on the FTR to provide greater clarity on a number of topics, including the Traceability Lot Code source reference, food traceability plans, and intracompany shipments.
The tabletop exercises fulfilled a Congressional directive under the Continuing Appropriations, Agriculture, Legislative Branch, Military Construction and Veterans Affairs, and Extensions Act, 2026 (P.L. 119-37).
Additional Information
FDA Public Meeting- Challenges and Solutions in Lot-Level Food Traceability
FDA Releases Discussion Paper Ahead of Traceability Public Meeting in June
FSMA Final Rule on Requirements for Additional Traceability Records for Certain Foods
Frequently Asked Questions