Blog | Retail Insight

Why FSMA 204 presents an opportunity for retailers

Written by Retail Insight Team | Mar 26, 2025 10:19:33 AM

The Food Safety Modernization Act (FSMA) Section 204 marks a pivotal moment for the food retail industry, spotlighting the vital role of food traceability. For grocery executives in the U.S. who are navigating ESG initiatives, food safety, and day-to-day operations, getting a handle on these changes is crucial.

Introduced by the Food and Drug Administration (FDA), FSMA 204 establishes new standards for traceability concerning foods listed on the Food Traceability List (FTL). This regulation requires all entities involved in manufacturing, processing, packing, transporting or storing these foods to maintain detailed records of Key Data Elements (KDEs) associated with Critical Tracking Events (CTEs). In other words, store operators will now be accountable to the regulation as well. The aim being to quickly identify and remove potentially contaminated products from the supply chain, to keep the public safe and healthy.

What are the KDEs and CTEs included in FSMA 204? 

Key Data Elements (KDEs) are specific pieces of information that must be recorded and maintained for each of the various CTEs:

  • Traceability Lot Code: A unique identifier assigned to a batch of food.
  • Product Description: Detailed information about the food, including its name and variety.
  • Quantity and Unit of Measure: The amount of food and the unit used to measure it (e.g., pounds, kilograms, liters).
  • Date of Harvesting: The date when the food was harvested.
  • Location Description: Information about where the food was harvested, processed, or packed.
  • Date of Receipt: The date when a facility or buyer received the food.
  • Date of Shipping: The date when the food was shipped to another entity.
  • Reference Document Type and Number: Any relevant documents and their identification numbers (e.g., invoices, bills of lading).

Critical Tracking Events (CTEs) are specific points in the food supply chain where traceability data must be captured and maintained:

  • Growing: Details about where and how the food was cultivated.
  • Creating: Information on combining ingredients to produce a new product.
  • Transforming: Documentation of any processing, cooking, or repackaging activities.
  • Shipping: Logs of when food is transported to another entity.
  • Receiving: Records of when food enters a facility or is received by a buyer.

What does FSMA 204 mean for grocery retailers?

While many upstream supply chain entities—such as manufacturers, processors, and distributors—have long been accustomed to stringent record-keeping and traceability protocols, FSMA 204 introduces new challenges for grocery retailers. Historically, retailers have focused on inventory management and point-of-sale data, with less emphasis on detailed traceability records. Now, they must adapt to comprehensive food traceability requirements, which include:

  1. Enhanced Recordkeeping: Retailers must now maintain detailed records of KDEs for foods on the FTL, ensuring that food traceability information is accurately captured and readily accessible.
  2. Rapid Data Accessibility: In the event of a food safety issue, retailers are required to provide food traceability information to the FDA within 24 hours, necessitating efficient data management systems.
  3. Supplier Verification: Retailers must ensure that their suppliers comply with FSMA 204 requirements, adding a layer of responsibility to verify that upstream partners maintain proper records and practices.
  4. Exemptions: Retailers are exempt from recordkeeping requirements for any food that is produced on a farm and both sold and shipped directly to the retailer. However, they must keep a record of the name and address of the farm for 180 days. 

How grocery retailers are preparing for FSMA 204

The requirements for FSMA 204 have implications for retailers that go beyond just the data they are required to amass and store. But this shouldn’t be seen as a burden, rather an opportunity. 

Whilst it might sound like a cliché, the work required to prepare offers retailers the opportunity to assess and potentially transform critical areas of their operations: 

  • Supply Chain: Retailers will need to work with their existing suppliers to ensure they can meet their obligations outlined within FSMA 204. While this will be focussed on ensuring they can access the relevant KDEs and CTEs, it also encourages greater collaboration and transparency while offering greater supplier verification opportunities. 
  • In-store Operations: from where and how data will be stored to the process of actioning a recall, retailers will need to have the right procedures in place to ensure FSMA 204 compliance. In doing so, however, you open up opportunities for automated data exchange and faster recalls, reducing manual errors and improving operational efficiencies. 
  • Labour Impacts: with the workforce already stretched, retailers need to consider how staff will be trained to understand traceability practices, implement clear roles for preventative controls, monitoring, and verification, provide regular updates, and ensure clear lines of communication. 

Opportunities for innovation

As part of assessing these areas of their operations in preparation for FSMA 204, retailers are presented with a golden opportunity to innovate. In doing so, they can limit manual workloads and improve efficiencies as part of any transformative work.

And this is where things get interesting. 

To meet the stringent food traceability requirements of FSMA 204, there are a number of innovations that retailers can and should consider to embrace automation, improve data collection, and reduce the labor burden:

  • 2D Barcodes: such as QR codes, encode detailed product information, enhance traceability and facilitate rapid data capture at various points in the supply chain. This technology also offers the opportunity for better in-store food waste practices and reduces the manual burden involved in expiration date management, and dynamic markdown practices. 
  • Radio Frequency ID Technology (RFID): RFID tags can track product locations and freshness in real-time, enriching inventory management and enhancing traceability compliance.
  • Automated KDE Data Platforms: These specialized systems automatically capture and manage traceability information—streamlining operations, improving data accuracy and ensuring compliance.

In fact, automation will play a pivotal role, creating a ripple of benefits such as reducing manual errors, increasing productivity, and transforming stores into efficient, data-centric environments. Retailers investing in process overhauls and staff training will lead the way in fostering a culture of food safety and accountability. 

Beyond compliance, these advancements enhance supply chain visibility, allowing for faster identification and removal of contaminated products, ultimately safeguarding public health while minimizing recall costs. Advanced tracking systems and automation not only streamline their operations but also drive cost savings and profitability. 

Those that embrace these technologies will gain a competitive edge by demonstrating a commitment to food safety and transparency—boosting consumer trust and brand loyalty. But they will also open the door to broader benefits that will positively impact in-store operations.

How FSMA 204 could unlock new opportunities with food traceability data and automation

Meeting the requirements of FSMA 204 without automation poses significant challenges. Manually tracking expiration dates and maintaining detailed records can be time-consuming and susceptible to human error, increasing the risk of non-compliance.

Retailers that embrace automation for FSMA 204 compliance gain access to a wealth of data that can drive sustainability, reduce waste, and improve operational efficiency. By going beyond compliance, they can turn traceability data into a powerful tool for ESG initiatives and smarter decision-making.

Consider the following scenarios:

RFID

If you're already tracking logistics through RFID and IoT, why not take it a step further? Machine learning models can analyze that data to predict risks, enabling real-time decisions—like markdowns, recalls, or redistribution—before waste happens. This data can also be directly tied to inventory records so that if something is damaged or at risk during transport, records update automatically, ensuring inventory accuracy and reducing unnecessary loss.

2D Barcodes

Unlock even more opportunities for automation, particularly in waste prevention. Expiration dates can be linked to sales trends and real-time inventory data, allowing retailers to optimize markdowns, forecast demand more accurately, and minimize overstock. Understanding the average shelf life of perishable goods compared to expiration dates ensures better inventory rotation, helping to sell products before spoilage occurs.

Traceability Data

Food traceability data also plays a critical role in recall management and product availability. Recalls impact not just safety but inventory levels and store operations. When this data is easily accessible, retailers can integrate it into predictive models to adjust stock levels proactively and make smarter replenishment decisions.

By using these insights, retailers can boost productivity, improve data accuracy, and create more efficient operations—all while making meaningful progress toward sustainability. FSMA 204 compliance isn’t just about meeting regulations; it’s an opportunity to rethink how data can drive smarter, more sustainable business decisions.

The next steps: from compliance to retail automation

As FSMA 204 drives greater traceability and data collection, we’re eager to see how retailers harness these insights to go beyond compliance. The ability to track inventory in real-time, optimize expiration management, and predict risks opens the door to smarter automation, better decision-making, and more sustainable retail operations. The real opportunity isn’t just in meeting regulations—it’s in using these data sets to drive profitability, reduce waste, and enhance efficiency across the supply chain.

At Retail Insight, we see these changes as a chance to empower retailers with solutions that transform compliance into a competitive advantage. By leveraging automation and AI-driven insights, our tools help retailers take full advantage of their data—whether it’s optimizing markdown strategies, improving inventory accuracy, or ensuring products are sold before they expire. With real-time intelligence, retailers can reduce waste, increase sell-through rates, and make operations more efficient without adding complexity to their workflows.

As the industry evolves, we’re excited to be at the forefront, helping retailers unlock the full potential of their data to drive smarter, more sustainable decisions.

Curious how to automate processes using traceability data?

Retail Insight turns your wealth of data into actionable insights that maximize your retail potential. Our data-driven solutions empower retailers to leverage their traceability data, so you can stay compliant with regulations while addressing operational challenges. With real-time data and AI-powered insights, we help you enhance key processes like on-shelf availability, inventory accuracy, markdowns and more, all while cutting down on food waste and inefficiencies.

Our advanced systems spot trends in your data, allowing you to make proactive decisions that align with sustainability goals and meet consumer expectations. Plus, by automating routine tasks and enhancing existing processes with improved insights, your teams can work more efficiently and concentrate on more critical, customer-facing activities. This ultimately boosts overall store efficiency and enhances customer loyalty.

Ready to revolutionize your stores? Let’s explore our innovative solutions and prepare your stores for a future driven by efficiency, safety, and sustainability.