The food and beverage industry is facing a critical moment as the FDA’s Food Traceability Rule (FSMA 204) draws closer to its January 2026 deadline. This regulation is designed to enhance food safety and transparency by ensuring that supply chain participants can quickly and efficiently share traceability data when it matters most. However, achieving compliance isn’t without its challenges, and supply chain digital transformation, while seemingly a no-brainer for efficiency and growth, faces significant barriers, concerns, and hurdles that organizations must overcome to succeed.
A recent Food Navigator article highlighted some of these challenges—outdated systems, concerns about excessive technology, and potential vendor lock-in. As someone deeply embedded in the food traceability space, I wanted to share my perspective on these critical points. As the deadline approaches, it’s clear that compliance is about much more than just producing a report—it’s a call to action for the entire industry to modernize and embrace supply chain digital transformation.
Outdated systems—not too much technology—are the real barrier to supply chain digital transformation
I applaud the leadership that many retailers are taking to push FSMA 204 forward. But the real barrier lies with outdated systems, not too much tech. The industry is grappling with reliance on legacy systems (and processes that haven’t kept pace with digital advancements) to manage supply chains. Industry outsiders simply can’t believe some of the most advanced supply chains in the world still run on pen and paper, but the fact remains. This technological debt has created a significant hurdle, as the industry now faces the daunting task of implementing what other industries have been doing for over a decade. But now, it must be implemented in an extremely compressed timeframe.
If your operations are complex, implementing FSMA 204 will require digitizing information and processes deploying systems like MES, WMS, DMS, symbology capture, and more. It will be complex, and it will be messy—but it’s a must. FSMA 204 isn’t just about producing a report; it’s about connecting data points at scale and operationalizing that data. The report is simply the result—collateral, if you will. The real focus should be on building smarter, more resilient supply chains through supply chain digital transformation, enabling the industry to adapt and grow.
Vendor lock-in could undermine the ecosystem
One concern raised in the article is the potential for vendor lock-in, and this is something I find troubling. FSMA 204 was designed to allow supply chain participants to implement systems and technologies that are best suited to their unique operations. However, we’re seeing some cases where retailers are pushing for platform homogenization across their supply chains. While this might benefit individual vendors, it risks being counterproductive for the broader ecosystem.
As a vendor, I firmly believe in the importance of maintaining an open and adaptable environment. Cooperation between competing platforms is key to fostering innovation and ensuring that FSMA 204 achieves its intended impact. Forced standardization could limit flexibility, hinder progress, and ultimately create more challenges than it solves.
Interoperability is the foundation
The emphasis on interoperability within FSMA 204 is one of its greatest strengths. Different value-chain participants should be able to transact an agreed-upon set of data elements, regardless of the platform they’re using. Whether the data is exchanged via EDI, EPCIS, DESADV/RECADV, or even spreadsheets, systems must be capable of handling diverse formats from multiple sources.
If a platform lacks this capability—or lacks a plan to implement it in short order—it raises serious questions about its viability. Interoperability ensures that supply chain participants can collaborate effectively, even when using different technologies, and this is critical for the success of FSMA 204 and for advancing supply chain digital transformation.
I can’t help but add a shameless plug and highlight the great work the GS1 US FSMA 204 workgroup has been doing in outlining implementation guidelines.
Compliance as an opportunity
I also can’t help but overstate that the journey to FSMA 204 compliance isn’t just about meeting regulatory requirements—it’s an opportunity to embrace digital transformation. Organizations that prioritize openness, interoperability, and system modernization will not only comply with the regulation but also turn compliance costs into strategic investments.
By implementing FSMA 204, companies can unlock better efficiency, transparency, and actionable insights, which will drive long-term growth and resilience. Yes, the process may be challenging, but the benefits far outweigh the initial complexity.
What to look for in a traceability solution to achieve compliance and enable a painless supply chain digital transformation
For those evaluating traceability solutions, I’d suggest focusing on three key criteria: scalability, interoperability, and integrability. These attributes are essential for navigating the complexities of today’s supply chain environment and ensuring that FSMA 204 compliance delivers value beyond the regulation itself. Get in touch if you want to learn more and discuss.
You might also find this interesting
- Our thoughts on overcoming the challenges of food traceability
- A deeper dive into FSMA 204 with our e-book From Compliance to Opportunity: FSMA 204