Why retailers want your traceability data before the 2028 deadline

When the FDA moved the FSMA 204 compliance date from January 2026 to July 20, 2028, a lot of small food companies relaxed. That is understandable. It is also a risk, because the companies that buy your product did not move their own timelines.

What buyers are asking for

Large retailers and foodservice distributors have been building traceability programs for years. Walmart, for example, told suppliers of certain fresh foods to send traceability data with advance ship notices and to use GS1-128 case labels starting in August 2025. Other chains and distributors have their own supplier requirements, usually written into vendor agreements.

The details differ, but the requests tend to include:

• Lot codes on every case, usually as a GS1-128 barcode alongside the product’s GTIN.
• Advance ship notices (ASNs) sent electronically before the truck arrives, listing products, quantities and lot codes.
• Key data elements that line up with the FDA rule, so the buyer can meet its own obligations.
• Mock recall participation, where the buyer asks you to trace a lot on short notice.

If you sell to a large retailer, read your current supplier agreement or portal notices. Requirements are often updated there first.

Why buyers care now

A retailer that receives listed foods is covered by the same rule. To keep its own records, it needs yours. Collecting that data from thousands of suppliers takes years, so buyers started early and pushed the work upstream.

There is also a business reason. When a recall happens, a retailer that can identify exactly which lots it received can pull a few pallets instead of an entire category. Suppliers who make that easy are easier to keep.

The squeeze on small suppliers

Big suppliers have EDI teams and enterprise traceability systems. Small producers and regional distributors usually have a few people, a label printer, an accounting package and a lot of email. Meeting a buyer’s ASN and labeling requirements with that setup often means:

• Paying an EDI provider per transaction
• Reformatting the same shipment data for each customer
• Retyping lot codes from labels into spreadsheets
• Hoping nothing goes wrong during a busy week

A practical path

1. Start with the customer that asks the most. Meet their requirements fully before generalizing.
2. Standardize lot codes and labels so the same code appears on the case, the invoice and the bill of lading.
3. Capture lot codes at receiving and shipping, not after the fact.
4. Keep your data in one place that can produce both a buyer’s format and FDA’s sortable spreadsheet.
5. Ask your buyers for their mock recall schedule and practice before they call.

Where Lotcrumb fits

Lotcrumb is being built so a small team can keep one set of traceability records and export it in the formats buyers and FDA ask for. Join the waitlist for early access and founding pricing.

This guide is general information. Retailer requirements change often, so confirm details in your supplier agreement.