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The Food Traceability Rule took effect in January 2023, but a provision in a 2025 federal law bars FDA from spending funds to administer or enforce it before July 20, 2028. FDA is holding a public meeting on lot-level traceability, with registration and written-comment deadlines in October and December 2026. The source report says why lawmakers and the agency accepted the delay, but its supplied text ends before completing that discussion.
Congress has barred the Food and Drug Administration from using funds to administer or enforce the Food Traceability Rule before July 20, 2028, even though the rule took effect in 2023. The funding restriction, enacted in November 2025, leaves the rule on the books while postponing federal enforcement and requires FDA to meet with affected businesses about ways to implement lot-level tracking.
FDA will hold a public meeting on Nov. 6, 2026, titled “Challenges and Solutions in Lot-Level Food Traceability.” People who want to speak must register by Oct. 26; the meeting notice does not allow same-day registration. Written comments are due Dec. 6 in Docket No. FDA-2014-N-0053. The source report describes the meeting as an opportunity to discuss implementation, while arguing that its focus on lot codes could also lead to discussion of ways to reduce the burden of that requirement.
The rule covers specified foods, including leafy greens, tomatoes, cucumbers, melons, sprouts, fresh-cut produce, shell eggs, some cheeses and seafood, as well as ready-to-eat deli salads. Covered businesses must record key information at events such as harvesting, packing, shipping and receiving, and link records through a traceability lot code. When FDA requests records during an outbreak, companies must provide an electronic, sortable spreadsheet within 24 hours, according to the report.
Section 780 of Division B of Public Law 119-37, signed Nov. 12, 2025, prevents funds appropriated by that law from being used to administer or enforce the rule before July 20, 2028. It also directs FDA to hold quarterly meetings with farms, restaurants, retailers and warehouses; develop guidance on specified operational issues; and test the agency’s internal tracing system. The source report says FDA had previously announced a proposed 30-month compliance extension, but that the proposal had not been finalized. Congress’s funding restriction now sets the enforcement limit described in the report.
Traceability Without Federal Enforcement
The rule is intended to help investigators connect contaminated food to its source more quickly during an outbreak. The report says earlier FDA pilot projects found that conventional “one step forward, one step back” records often failed to link restaurants or grocery stores where illnesses were reported to the farms that produced the food. Lot codes are meant to bridge that gap by connecting records across the supply chain.
The delay matters for both public health and businesses. Without federal administration or enforcement before July 20, 2028, companies have more time before facing the rule’s federal requirements, while investigators and consumers may wait longer for the system intended to speed traceback. The law also requires FDA to work with businesses on flexibilities, so the eventual implementation could reflect guidance developed during those meetings. The supplied report does not establish how much the delay will affect outbreak investigations or the readiness of individual companies.
food traceability software lot tracking system
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A Rule Delayed After Enactment
Congress directed FDA in Section 204 of the 2011 Food Safety Modernization Act to identify foods associated with outbreaks and require stronger records for their production and movement. FDA missed the original deadline to propose a rule. After food-safety groups sued in 2018, a consent decree set a schedule; FDA issued its final rule on Nov. 21, 2022. It took effect Jan. 20, 2023, with compliance originally set for Jan. 20, 2026.
FDA later said routine inspections would not begin until 2027. In March 2025, the agency announced its intention to move the compliance date by 30 months, to July 20, 2028, citing supply-chain partners that were not ready. FDA said then that the extension would not change the rule’s requirements. Congress subsequently included the funding restriction in the law ending the government shutdown, making the pause a statutory limit on the agency’s use of funds rather than only a proposed agency schedule.
The Congressional Research Service estimate cited by the report puts the rule’s reach at more than 323,000 domestic businesses, operating about 484,000 establishments. Those figures describe the estimated scope of the rule, not the number of businesses currently prepared or compliant.
“A funding bar is Congress taking away the agency’s ability to change its mind.”
— Food Safety News report
Questions on Implementation Remain
The source material does not include FDA’s detailed agenda for the Nov. 6 meeting or explain which specific lot-code flexibilities the agency may consider. It also does not report how many businesses have adopted systems that meet the rule’s requirements, or whether the quarterly meetings have produced guidance or changes in practice.
The report states that FDA’s proposed extension had not been finalized when it was written. The congressional funding restriction is described separately and prevents covered federal spending before July 20, 2028; the supplied material does not explain whether FDA has issued later clarifications on the proposal or how it will carry out each required activity under that restriction. The source excerpt also ends before completing its discussion of industry lobbying and congressional involvement, so it does not support a full account of who sought the delay or why each supporter backed it.
Meeting and Comment Deadlines
People seeking to speak at FDA’s Nov. 6, 2026, meeting must register by Oct. 26. Written comments on the lot-level traceability discussion are due Dec. 6 under Docket No. FDA-2014-N-0053. FDA is also directed by law to meet quarterly with representatives of farms, restaurants, retailers and warehouses, issue guidance on specified food-recovery and transfer issues, and test its internal tracing system.
The next major date in the statute is July 20, 2028, before which the law bars the covered use of funds to administer or enforce the rule. The supplied material does not identify a later FDA decision or additional compliance milestone. Businesses and readers will need to watch for FDA meeting records, guidance and any official updates that clarify how the agency plans to prepare for that date.
Key Questions
Is the Food Traceability Rule in effect?
It took effect on Jan. 20, 2023. A provision in the 2025 law bars FDA from using covered funds to administer or enforce it before July 20, 2028; the rule itself remains on the books.
What information does the rule require businesses to keep?
Covered businesses must record key data at specified events, including harvesting, packing, shipping and receiving, and connect records using a traceability lot code. The rule applies to designated foods on FDA’s Food Traceability List.
When is FDA’s public meeting, and how can people participate?
The meeting on lot-level food traceability is scheduled for Nov. 6, 2026. Those who want to speak must register by Oct. 26. Written comments are due Dec. 6 in Docket No. FDA-2014-N-0053.
Does the law permanently remove the lot-code requirement?
No. The source material describes a bar on federal administration or enforcement before July 20, 2028, alongside required meetings and guidance on implementation. It does not say Congress repealed the rule or removed the lot-code requirement.
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