Food and beverage manufacturers operate under two sets of rules. The federal one and the customer one.
Right now the customer one is binding and the federal one is not, which is the opposite of what most suppliers assume. A large number of food companies stood down on traceability work in 2025 after reading a headline about a delay, and some of them are absorbing chargebacks today because of it.
Start there, then work through the operational layers.
The Deadline That Moved, and the One That Did Not
FSMA 204, the Food Traceability Rule, was originally set for January 20, 2026. It now takes effect July 20, 2028.
The sequence matters, because it tells you how firm that new date is. FDA announced its intent to extend in March 2025 and published the proposed 30-month extension in the Federal Register on August 7, 2025. Then, in November 2025, Congress passed the Continuing Appropriations Act of 2026 directing FDA not to enforce the rule before July 20, 2028, and FDA is complying.
Two consequences.
The delay is Congressional now, not just agency discretion. A further extension would require either Congressional action or new FDA rulemaking, and there is no public signal that either is coming. Plan as though July 20, 2028 is firm.
The rule itself did not change. FDA’s own guidance is clear that only the compliance date moved. Entities that manufacture, process, pack, or hold foods on the Food Traceability List still have to assign Traceability Lot Codes, capture Key Data Elements at Critical Tracking Events, maintain a traceability plan, and produce records to FDA within 24 hours of a request. Exemptions are narrow, covering farms under $25,000 in annual food sales, very small businesses under $250,000, retail establishments selling direct to consumers, and foods passing through a kill step. Most food manufacturers qualify for none of them.
And here is the part that should change your planning.
Walmart’s supplier traceability requirement, which calls for advance ship notices carrying KDE data, SSCC-18 pallet labels, and GS1-128 case labels, took effect August 1, 2025. Chargebacks for non-compliant shipments are being assessed now, not in 2028.
So if you sell into mass retail, the federal date stopped being the date that drives your project plan some time ago.
Confirm your own requirements through your customer’s supplier portal. Retailer traceability mandates differ in scope, timing, and label specification, and summaries written by software vendors have an incentive to describe them as broader and more urgent than they are. Get the specification from the buyer.
Traceability Is a Logistics Problem, Not Only a QA Problem
This is the framing error that puts food companies behind.
Traceability projects usually land with quality or IT. But two of the Critical Tracking Events under the rule are shipping and receiving, which are logistics events. The data has to attach to the physical movement of goods, not to a batch record sitting in a separate system.
Which raises a question worth asking this quarter. Does your shipment record carry lot-level data, or does it carry a bill of lading number?
If your ASN cannot transmit traceability lot codes and the associated data elements to your customer, your traceability plan does not function regardless of how good your ERP is. The information has to move with the freight and arrive in a format the receiver can consume. EPCIS is the standards-based format the industry uses for sharing this data between trading partners, and it is worth knowing whether your systems and your logistics provider’s systems can speak it.
The practical test: pick a shipment from last month and try to produce, in under an hour, every data element the rule would require for it. Whatever you cannot assemble is your gap list.
The Sanitary Transportation Rule Puts the Burden on the Shipper
FSMA’s Sanitary Transportation of Human and Animal Food rule assigns responsibilities across four parties: shippers, loaders, carriers, and receivers. Most food manufacturers are the shipper, and the shipper carries more of the load than people expect.
In broad terms, the shipper is responsible for specifying in writing the operating temperature and sanitary conditions the carrier must maintain, unless those responsibilities have been assigned differently by written agreement. Carriers must train personnel in sanitary transport practices and keep records of that training. Written agreements establish who is doing what.
The most common failure here is not a missing document. It is a vague one.
“Keep it cold” is not a specification. A specification is a set point, a tolerance, a monitoring method, and a defined action if the reading goes out of range. If your carrier instructions do not contain all four, you have a written agreement that will not help you in a dispute.
Three questions to answer honestly:
- Do we have written agreements in place with every carrier hauling our product, including brokered capacity?
- Does every load tender state the temperature and the tolerance, in writing?
- If a customer or FDA asked, could we produce the carrier training records the rule contemplates?
If a third party arranges your freight, ask them the same three questions about their carrier base.
The Cold Chain Failure Nobody Designs For
One sentence prevents more product loss than anything else in this article.
A refrigerated trailer maintains temperature. It does not reduce it.
Reefer units are engineered to hold product at a set point and remove ambient heat gain through the trailer walls. They are not sized to pull down the temperature of a warm load. Loading product above target and expecting the unit to fix it during transit is the single most common cold chain failure in food logistics, and the product arrives out of spec even though the trailer ran perfectly the whole way.
Four practices that follow from that:
Pre-cool both the trailer and the product. The trailer should be at set point before loading begins, and the product should already be at its target temperature when it goes on.
Measure pulp temperature, not just air temperature. The reading that matters is inside the product. Air temperature at the return sensor can look correct while the pallet core is warm.
Use continuous monitoring rather than min/max recorders. A min/max device tells you something went wrong. Continuous data tells you when and where, which is the difference between a claim you can support and a dispute you will lose.
Document set point and actual, separately. A load can run at the correct set point and still fail if the unit cycled, a door stayed open at a stop, or airflow was blocked by the load pattern.
Load pattern deserves its own mention. Reefer airflow needs a return path. Freight stacked tight to the walls and the front bulkhead blocks circulation, and the pallets in the dead zone are the ones that fail.
The Retail Performance Layer
This is where food manufacturers lose margin without seeing it in the freight budget.
On-time in-full requirements and must-arrive-by-date windows carry chargebacks assessed per shipment. A load that arrives a day early can be penalized the same as one that arrives late.
Appointment compliance at distribution centers is its own discipline. Missing a scheduled window can mean a reschedule days out, which then cascades into an OTIF failure.
Shelf-life-remaining requirements convert transit time into a commercial constraint. Retailers commonly require a minimum percentage of remaining shelf life at receipt, which means a slow lane or a delayed load can render a shipment rejectable even though the product is perfectly safe.
Lumper fees at grocery distribution centers are near-universal in this vertical and frequently unmanaged. Establish in advance who pays, how receipts are captured, and how reimbursement flows, or these accumulate as unreconciled charges.
Pallet programs matter more in food than in most verticals. Pooled pallet requirements and exchange policies vary by receiver, and getting them wrong produces both fees and delays at the dock.
The structural problem with all of these is accounting. Chargebacks land in customer deductions rather than in the transportation line, so the freight budget looks fine while the margin erodes somewhere else. Ask whether anyone in your company is reporting deductions by root cause. If nobody is, that is the number to build first.
Where Food Freight Differs Operationally
Five things that make this vertical harder than dry freight.
Trailer sanitation and prior load restrictions. Washout requirements and prior-cargo declarations are standard for food-grade moves. Ask what your carrier’s washout documentation looks like and whether you receive it.
Allergen exposure in consolidated freight. LTL freight shares a trailer with other shippers’ product. For allergen-sensitive goods, that consolidation carries a risk that does not exist in a dedicated truckload.
Temperature-controlled LTL is a thin market. There is far less refrigerated LTL capacity than dry LTL capacity, and lanes that work easily dry can be difficult and expensive cold. Partial truckload is often the better answer for volumes that fall between.
Inbound ingredient coordination. Most food logistics attention goes to outbound finished goods, while inbound ingredient timing is what actually constrains production. A missed inbound is a lost production run, which costs more than any freight premium.
Co-packer networks add a leg. Every additional handoff between your plant, a co-packer, and the customer is another set of Critical Tracking Events and another place for lot data to break.
Because timing and temperature both matter, this is a vertical where warehousing and freight need to be coordinated rather than bought separately.
A Practical Readiness Check
Work through these in order. Each produces something usable.
- Confirm your customer requirements from the source. Pull the traceability and labeling specification from each major customer’s supplier portal, not from a summary.
- Test one shipment end to end. Pick a recent load and try to assemble every data element the traceability rule would require. The gaps are your project plan.
- Audit your written carrier agreements. Confirm they exist, and confirm they contain a temperature set point, tolerance, monitoring method, and out-of-range procedure.
- Check your monitoring hardware. Continuous or min/max, and who receives the data.
- Report deductions by root cause for one quarter. Separate OTIF, appointment, shelf life, labeling, and lumper charges. Most companies have never seen this split.
- Review your inbound lanes, not just outbound. Production stoppages cost more than freight.
Frequently Asked Questions
Does the FSMA 204 Extension Mean We Can Wait?
No, for two reasons. The Congressional directive makes July 20, 2028 firmer than a typical agency delay, and building traceability across trading partners takes years rather than months. More immediately, retailer requirements are already live and generating chargebacks regardless of the federal date.
Who Is Responsible if a Reefer Fails in Transit?
It depends on what your written agreement says, which is exactly why the agreement matters. Responsibility allocation among shipper, loader, carrier, and receiver is the mechanism the sanitary transportation rule uses. Vague instructions tend to resolve against the party that wrote them.
Should We Use a Dedicated Carrier or a Broker for Temperature-Controlled Freight?
Both models work. What matters is whether the party arranging the freight maintains written agreements, verifies carrier training and equipment, and can produce documentation when a customer or regulator asks. Ask for the process, not the promise.
How Much Shelf Life Do Retailers Require on Arrival?
It varies by retailer and product category, and it is specified in your vendor agreement rather than by regulation. Find your number, then work backward through transit time and dwell to see how much slack you actually have. Many suppliers discover they have less than they assumed.
Start With One Shipment
The most useful diagnostic in this article costs nothing. Take a single recent load and try to produce, in one hour, the full traceability record, the temperature documentation, and the written carrier instruction that governed it.
Whatever you cannot assemble is the work.
ATS Logistics has arranged freight since 1980 across LTL, full truckload, drayage, expedited, and international moves, with warehousing available where storage and freight need to move together.
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