Food Manufacturers Pursue Traceability in an Uncertain Regulatory Environment

Food manufacturers continue investing in advanced traceability equipment and technology as federal and state regulations shift. Customer requirements for lot tracking remain strong, data-standardization initiatives continue to gain traction, and companies are pursuing continuous improvement despite the uncertainty.

Some food manufacturers are adding more magnetic inspection units upstream to reduce risk.
Some food manufacturers are adding more magnetic inspection units upstream to reduce risk.
Industrial Magnetics

The FDA paused FSMA 204, but traceability technology, innovations and applications are moving forward in food manufacturing. Retail customers’ requirements for lot tracking aren’t slowing, and companies are pursuing continuous improvement amid regulatory uncertainty.

The state of West Virginia banned petroleum-based food dyes in 2025 via HB 2354. However, just seven days into 2026, a federal court delivered a preliminary injunction in favor of the International Association of Color Manufacturers due to a lack of definition around the words “poisonous” and “injurious” in the bill. In essence, the court said there was insufficient scientific support for the state ban.

While unexpected state laws emerged in 2025, the Food and Drug Administration (FDA) delayed Food Safety Modernization Act (FSMA) Rule 204 by 30 months, a move announced in March 2025. Rule 204 is intended to enable identification of food safety incidents within 24 hours through digital records and lot-level tracking throughout the supply chain.

“I don’t believe the staff changes at the FDA had much to do with the 30-month extension,” says Dr. Jennifer McEntire, Founder of Food Safety Strategy. “The FDA realized it would be impossible to enforce the rule if the Jan. 2026 date had stood.”

Despite shifting federal and state regulations, food manufacturers continue investing in advanced traceability equipment and technology. Customer requirements for lot tracking remain strong, data-standardization initiatives continue to advance, and companies are pursuing continuous improvement regardless of regulatory uncertainty.

Secrecy Around FSMA 204

The FDA announced a comment period for the Food Traceability Rule in February 2026. However, the comment period did not include the public and was limited to the Partnership for Food Traceability (PFT), an organization of approximately 10 food companies.

Congress added the new comment period through the 2026 appropriations bill. McEntire highlighted the development in February and raised concerns about the limited access to stakeholder feedback opportunities:

“FDA’s February 2026 announcement related to food traceability contained a concerning, and to the best of my knowledge, unprecedented statement indicating that the only listening session scheduled prior to the close of the comment period for the draft guidance will be limited to paying members of the Partnership for Food Traceability.”

On March 6, the PFT and FDA held the meeting and established a framework focused on lot-level tracking. Objectives included:

  • Identifying points in the supply chain where lot-level tracking has the potential to break down;
  • Examining the challenges those breakdowns create for establishing traceability;
  • Identifying and discussing specific potential solutions to those challenges, including potential regulatory flexibilities, to comply with the lot-level tracking requirements in the Food Traceability Rule.

“In addition to several supportive comments on my related LinkedIn post, I also heard from several others individually, including a few involved in PFT,” says McEntire. “I don't think anyone likes the idea of secrecy.”

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