The original date of compliance for the FDA (Food and Drug Administration) FSMA (Food Safety Modernization Act) Rule 204 was January 20, 2026. This deadline date has been extended to July 20, 2028. The FDA FSMA Rule 204 requires that food and beverage companies with ingredients on the FDA Food Traceability List maintain a searchable database that digitally tracks the supply chain journey of these ingredients through and including to the final product.
Whether the FDA will again extend the deadline for FSMA Rule 204 compliance is unknown. But for retailers and grocers, many expect lot/batch, manufacturing date, and expiration date data now – not later – as part of their supply chain requirements. These major retailers are grocers are not waiting. And for some retailers and grocers, they are extending the coverage of who needs to submit FSMA data to all food and beverage vendors, not just those who have products with ingredients on the FDA’s Food Traceability List.
For consumer brands who are the retail and grocery vendors, just meeting regulatory compliance is therefore not good enough: this is now also a supply chain compliance issue. It is insufficient to just maintain a separate, isolated database (the FDA considers a spreadsheet an allowable database) of traceable information for ingredients. How will the traceability data and database integrate with other supply chain systems and allow this information to flow through and ultimately be received by the retailers and grocers?
The FSMA data is conveyed to retailers and grocers via X12-EDI in the EDI856 ASN (Advance Ship Notice). This means that any traceability database needs to be integrated to a vendor’s production system, warehouse system, and ERP (Enterprise Resource Planning) system before the data reaches the vendor’s EDI system.
If the vendor uses third-party logistics warehouses (3PL), all inventory transfers (e.g., via the EDI943 Warehouse Stock Transfer) need to include the FSMA product data – lot/batch identifier, manufacturing date, expiration date – so that the 3PL can include this data on paper documentation and in electronic transactions such as the EDI856 and the EDI945 Warehouse Shipment Advice. If the vendor fulfills from their own warehouse, the FSMA requirements remain the same as do how the data reaches the retailer or grocer.
X12-EDI is viewed as either a technical nuance, nuisance, or necessity depending upon the perspective. But the reality is that EDI – along with the ubiquitous barcode – is one of the foundational technologies of supply chains. Whether EDI is “uppercase” as in the X12 standards or “lowercase” as in the use of any other form (e.g., HTML or CSV file) of data exchanged, the data exchanged between two trading partners really just conveys what is operationally occurring in the respective business. Getting the data correct – and complete – is a requirement to ensure that the business relationship is strong.
In February 2005, Dr. Edward J. Marien published an article titled “The Customer’s Bill Of Rights” in what was then called Logistics Magazine but is now known today as Material Handling & Logistics. Dr. Marien’s eight rights – also known as his 8 Rs – still resonate today as the definition of what a perfect order should be.
- The Right Product.
- In the Right Quantity
- From the Right Source
- To the Right Destination
- In the Right Condition
- At the Right Time
- With the Right Documentation
- At the Right Cost
I will add that a nineth right should be added: With the Right Data. While it is true that the right data should be inherent to all points of the perfect order and order fulfillment process and a characteristic of every paper document (including barcode labels) and all electronic transactions, I believe that the Right Data deserves its own callout and rightfully so at the end of Dr. Marien’s list.
The data needs to be “right” in terms of it being accurate. That’s a given, and I think that was assumed by Dr. Marien when he first created his list. With regulatory requirements merging with supply chain requirements, the “right” data now represents including all necessary data to ensure that the data completely meets – or exceeds when permissible – recipient trading partner requirements.
When it comes to conforming with retail or grocery supply chain requirements, anything less than perfect risks being financially penalized with chargebacks for non-compliance. Not only are chargebacks expensive, but they count as knocks against vendor scorecard performance metrics. Retailers and grocers don’t want to work with disruptive partners that cause operational chaos and drive up the cost of conducting business.
In a commoditized world, execution is the new competitive edge. Consumer brands that can out-execute their competitors by better integrating themselves with their retail or grocery trading partners stand a better chance of keeping their competitors out of the picture. This means more than just connecting systems and swapping transactions. This means that the quality and the substance of the transactions matter. It’s all about the data, just as it always has been and will continue to always be.
Consumers increasingly care about the life story of the products that they are purchasing. From the list of ingredients to their sources, retailers, grocers, and consumers want more and more information, and want it conveniently. The GS1 Sunrise 2027 initiative to transition product barcodes from the familiar 1D (one-dimensional) linear barcode to 2D (two-dimensional) barcodes will open up a world of information to consumers for brands that avail themselves of the opportunity to capture traceability data and put it in a user-friendly format accessible regardless of device.
Execution is about more than just transactions these days. It’s about experience too. The brands that get it will be the ones that win with their trading partners and with the consumers, regardless of where and how they shop. It all starts with the right data creating the right experience.
