Since FDA’s Food Traceability Final Rule was published more than seven months ago, FMI members have been working tirelessly to understand the rule in order to develop and implement solutions to meet the requirements by the 2026 compliance date. While the concept of tracing food from farm-to-fork may sound simple at first, in reality, it is quite complex.
Some of these challenges stem from the fact that:
- Every food is different.
- Every company is different.
- Every system is different.
- Every business model is different.
- Every supply chain is different.
But, it is these differences that contribute to a successful food system. They spur innovation and growth and allow access to affordable food to even the most rural places in the United States. Despite this, these differences create significant challenges for companies trying to meet the requirements of the food traceability rule.
To help overcome some of these challenges:
- Standardized information is needed.
- Communication among supply chain partners is needed.
- Technology to facilitate information sharing is needed.
- New systems and processes are needed to capture the correct information while trying to maintain operational efficiencies.
Leveraging data standards can be helpful in meeting these needs—streamlining business processes, enhancing supply chain visibility, enabling traceability and ultimately meeting the requirements of the rule. GS1 standards are the most widely used system of standards in the world.
While voluntary, GS1 standards provide a common foundation for businesses to uniquely and consistently identify products, assets, shipments and physical locations throughout the supply chain while also enabling trading partners to exchange critical information.
With a rich history, GS1 standards are an established tool that companies can leverage to help meet the requirements of the traceability rule. To assist the food industry with implementing GS1 Standards for traceability more generally, and specifically to help meet the requirements outlined in the Final Rule, GS1 US created an implementation guide, Application of GS1 System of Standards to Support FSMA 204.
Here are a few examples of how GS1 standards could be applied to align with the Key Data Elements (KDEs) required for Critical Tracking Events (CTEs) under the rule: