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FSMA 204 Compliance for Produce – How Are Companies Managing Traceability?

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FruitCompliance

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Posted 05 March 2025 - 05:47 PM

Hello,

 

In advance, thanks for sharing your time and knowledge.

 

We have products in the FTL list, and even though we participated in several webinars, a few meetings with companies that provide FSMA 204 and traceability solutions, we still do not have it clear how all these data and requirements should carry over in real life, or even how to begin with.

 

Do we need a platform, if so, what is the most popular? Would we be able to do it ourselves? How are other companies handling it? 

 

Looking for input from all sectors, would appreciate it even more if there is anything specific for fresh fruits. We are a receiver, shipper and the most transformation we handle are repacks and relabeling.

Thank you!


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Shamanthaksugh

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Posted 05 March 2025 - 07:37 PM

Hi,

As per FDA there is no requirement of a platform. The only requirement is that you have to submit an excel file that can be filtered, and they have uploaded a sample form on the website that you can download and use. Having said that, depending on the complexity of your situation, having a platform will definitely make life easier. In my case I only have to track receiving KDE, which was already being done as part of our traceability program and we therefore decided to not use a separate platform. We have received request from our customers to sign up for their partner platforms like FoodLogiQ and iFoodDS where we would need to enter all the shipping KDEs (I didn't have to sign up since we do not ship any food on the FTL). So, in your case I would recommend signing up to a platform that would allows you to track incoming, transformation and shipping KDEs. I do not currently have a recommendation on the platform for you, but depending on how you receive your invoices/BOL, how you are currently tracking your transformations and send your invoices/BOLs to your customers, I would pick a platform that would incorporate all three of these tasks in one and makes your life easy. Similar to my situation, you will probably receive requests from your customers to sign up to their platforms and provide them all the shipping KDEs, and this can become an added cost. If you have already have a traceability program set up, you would need to modify it accordingly as well. I hope this helps.


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FruitCompliance

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Posted 06 March 2025 - 02:51 PM

Hi,

As per FDA there is no requirement of a platform. The only requirement is that you have to submit an excel file that can be filtered, and they have uploaded a sample form on the website that you can download and use. Having said that, depending on the complexity of your situation, having a platform will definitely make life easier. In my case I only have to track receiving KDE, which was already being done as part of our traceability program and we therefore decided to not use a separate platform. We have received request from our customers to sign up for their partner platforms like FoodLogiQ and iFoodDS where we would need to enter all the shipping KDEs (I didn't have to sign up since we do not ship any food on the FTL). So, in your case I would recommend signing up to a platform that would allows you to track incoming, transformation and shipping KDEs. I do not currently have a recommendation on the platform for you, but depending on how you receive your invoices/BOL, how you are currently tracking your transformations and send your invoices/BOLs to your customers, I would pick a platform that would incorporate all three of these tasks in one and makes your life easy. Similar to my situation, you will probably receive requests from your customers to sign up to their platforms and provide them all the shipping KDEs, and this can become an added cost. If you have already have a traceability program set up, you would need to modify it accordingly as well. I hope this helps.

 

 

Thank you, Shamanthaksugh,

 

We sure are receiving requests to join platforms, and will have your reply in mind.


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jfrey123

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Posted 06 March 2025 - 05:26 PM

Couple of our major retail/distribution customers have outlined compliance dates within the next few months to be ahead of FDA's Jan 2026 date.  Both are requiring electronic Advanced Shipping Notices (ASN's), and they want our GS1 pallet and case stickers to correspond to those ASN's.  One of the distribution customers we sell to is requiring we provide the ASN's through iFoodDS Trace Platform, with additional option of also forwarding through iTradeNetwork.  Other customer is the major retailer in the US, and they've outlined we have to provide ASN's (with more information than what is required by Rule 204 Shipping KDE's I might add), and while they haven't outlined a platform they want them submitted by I'm going to assume it will be via their in-house supplier portal.

 

We have at least 15 other customer "groups" we sell to, and 99% of our finished goods are Rule 204.  Waiting for the hammer to fall and see how many different platforms they want to require us to integrate with.  As they do, bourbon may become a normal ingredient in my morning coffee.

 

I'd previously mentioned there was at least one bill in congress which would delay and prevent FDA from implementing Rule 204 until additional studies have been conducted (minimum 2-year moratorium on enforcement).  Update I found this morning is that the bill died in the previous session and I do not see any new proposals to further delay.  Not to mention there's nothing to stop our customers from requiring it anyway.  

Text of H.R. 9027 (118th): Agriculture, Rural Development, Food and Drug Administration, and Related Agencies Appropriations Act, 2025 (Reported by House Committee version) - GovTrack.us

 

Buckle up kiddos, Rule 204 is on the horizon...


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