The US Food and Drug Administration (FDA) has introduced a blueprint for the ‘New Era of Smarter Food Safety’^[1], bringing in additional food traceability requirements for both exporters and local players.

From 20 January 2026, anyone who manufactures, processes, packs, or holds foods destined for the US market that fall on the FDA’s food traceability list (FTL) will have to meet additional traceability requirements.

This will include certain types of fruit and vegetables (such as melons, tomatoes, peppers, sprouts, leafy greens, and fresh-cut fruit), certain types of cheeses, finfish, crustaceans, shell eggs, bivalve molluscs (including oysters, clams, and mussels), nut butter, and herbs, among others.^[2]

Aside from those mandated under the ruling, the FDA is encouraging industry-wide voluntary adoption of the enhanced traceability practices.

The ruling is a huge step in efforts by the US to prevent the spread of foodborne illness by having enhanced traceability requirements across the supply chain.

These requirements include a need to capture and maintain records of key data elements (KDEs) associated with specific critical tracking events (CTEs). Firms will also need to provide information to the FDA within 24 hours in most cases.

Exporters to the US market, as well as suppliers and stakeholders within the US domestic market, will all need to have the capability to record and report CTEs and KDEs in place by January 20, 2026 – or face penalties.

These penalties range from product seizures and injunctions up to administrative detention (arrest and detention of individuals by the state without trial), mandatory recalls, and placing imported food products on import alerts to prohibit their distribution and sale.^[3]

Achieving compliance

Documentation required under the new ruling differs according to the type of supply chain activities a food on the FTL goes through – such as harvesting, cooling, initial packing, and shipping. However, there is an overarching Traceability Plan requirement that also applies to all actors covered by the food traceability rule.

This overarching requirement includes:

• An obligation to document and update descriptions of the business procedures in place to maintain records and identify foods on the FTL;
• Farm maps spanning areas in which food is grown or raised – including aquaculture; and
• How traceability lot codes are assigned.^[4]

Exporters can meet and comply with these requirements by starting to build up their capabilities and investing in the digital tools to capture and monitor supply chain activities, enabling end-to-end product and supply chain visibility.

Solutions such as TradeWindow’s FDA-award winning Assure+ (formerly Rfider), enhance transparency both within organisations and across the supply chain. They enable organisations to re-use data to build trust with businesses and consumers alike. These solutions also ensure that firms can meet increased obligations for reporting.

Using these tools, customers can provide select parties with permissioned access to blockchain-verified records, which prove end-to-end traceability of goods.

Assure+ supports the long tail of supply chains, providing solutions for small supply chain participants as well as large. Its interoperability and ease of use also makes the product just as strong a contender for those who are new to digital tools as those who have integrated them for years. Assure+ helps firms to provide an audit trail across every CTE and KDE along a product’s journey to market and supports blockchain where this is an operational requirement.

Without such a trail of evidence, it is difficult to prove traceability and provenance claims. Paper trails and rudimentary digital storage files can be altered and tampered with, as well as being subject to human error where manual input is needed.

Assure+ is already being used in the US domestic market, most recently via a partnership agreement with FoodChain ID, a leading provider of technology-enabled food safety, quality and sustainability solutions for the food and agricultural industry. In combination with FoodChain ID’s existing integrated platforms, this partnership will enable more compliance, safety, and transparency across customers’ supply chains.

Beyond compliance – unlocking value 

The benefits of digital traceability tools are not limited to regulatory compliance, with food safety and traceability also being of increasing concern for consumers in recent years.

The ability to prove provenance claims and validate the passage of goods along the supply chain is ever more essential for businesses to succeed in key markets.

With the rise of conscious consumerism across the globe, organisations and businesses can unlock value along the supply chain by moving beyond simple data-gathering to implement end-to-end traceability solutions.

Benefits for the end consumer include enhanced food safety, biosecurity, and the ability to identify environmental and ethical production characteristics such as animal welfare, sustainable production, and quality control in the products they choose – as products can be traced right back to their origins.

The ability to communicate these stories to consumers is the golden ticket for many firms who no longer necessarily compete on price for their slice of the consumer-pie, but on an array of sustainability and environmental, social and governance (ESG) measures.

Firms that adopt business models which highlight product sustainability and provenance stories are likely to meet, and stay ahead of, this changing consumer demand.

Traceability solutions are also of particular interest to boards, as listed companies across the globe are increasingly required to disclose their business practices and operations in annual ESG reporting. A traceability solution is vital to provide proof points and evidence that the company is fulfilling its claims across its supply chain.

For more information on TradeWindow Assure+ and how we can help, visit contact us.

[1] FDA, 2022: New Era of Smarter Food Safety, https://www.fda.gov/food/new-era-smarter-food-safety

[2] FDA, 2022: Food Traceability List, https://www.fda.gov/food/food-safety-modernization-act-fsma/food-traceability-list

[3] FDA, 2022: Frequently Asked Questions on FSMA, https://www.fda.gov/food/food-safety-modernization-act-fsma/frequently-asked-questions-fsma

[4] FDA, 2022: Food Traceability Rule: Critical Tracking Events (CTEs) and Key Data Elements (KDEs), https://www.fda.gov/media/163132/download