FDA Advances Food Traceability Rule With Guidance, Cottage Cheese Exemption, and Public Meeting
FDA issued guidance on the Food Traceability Rule, finalized an exemption for IMS-listed Grade A cottage cheese, and announced a June 15, 2026 public meeting on lot-level traceability, as Congress bars enforcement funding until July 20, 2028.
The U.S. Food and Drug Administration has taken several actions related to the Food Traceability Rule, including issuing guidance for industry, finalizing an exemption for certain cottage cheese products, and announcing a public meeting on lot-level traceability. These steps come as Congress has directed that no appropriated funds may be used to administer or enforce the rule prior to July 20, 2028.
The Food Traceability Rule, published on November 21, 2022, establishes additional recordkeeping requirements for those who manufacture, process, pack, or hold foods on the Food Traceability List. The list includes some fresh-cut produce, some soft cheeses, shell eggs, nut butters, and some seafood. The rule requires facilities handling these products to maintain specific records for critical tracking events in the supply chain — such as initial packing, shipping, receiving, and transforming — to help FDA rapidly identify recipients of these foods during foodborne illness outbreaks. Subject entities must provide FDA with specific information within 24 hours of a request during an outbreak or public health threat.
On February 19, 2026, FDA issued a questions-and-answers guidance document to assist industry with understanding the scope of the rule and meeting its requirements. The guidance addresses applicability to entities such as farms, farmers' market stalls, fishing vessels, first land-based receivers, retail food establishments, and restaurants. It also covers activities including intracompany shipments, commingling, initial packing, and transformation, as well as details about the exemption for raw molluscan shellfish and how to determine if a product is "fresh-cut" for the Food Traceability List.
Also on February 19, 2026, FDA published a notice finalizing an exemption for Grade "A" cottage cheese that appears on the Interstate Milk Shippers (IMS) List from the requirements of the Food Traceability Rule. FDA concluded the exemption is warranted because the processing requirements specified in the Pasteurized Milk Ordinance for IMS listed Grade "A" cottage cheese address the risk factors that resulted in cottage cheese being on the Food Traceability List, and because of the enhanced oversight through the IMS program. Facilities that manufacture, process, pack, or hold IMS listed Grade "A" cottage cheese will still be required to maintain records identifying the immediate previous source and the immediate subsequent recipient of such food.
FDA is hosting a public meeting on June 15, 2026, to give the public an opportunity to share information on implementation of the Food Traceability Rule and areas of remaining concern, specifically related to lot-level tracking and flexibilities for compliance. The meeting is part of a series of engagements being held in accordance with a directive from Congress in the Continuing Appropriations, Agriculture, Legislative Branch, Military Construction and Veterans Affairs, and Extensions Act of 2026. General registration remains open until June 14, and individuals who wish to speak during the public comment period must register by June 5.
FDA also announced a series of quarterly stakeholder engagement sessions organized by the Partnership for Food Traceability, to fulfill the same congressional directive. These engagements will include regulated entities such as farms, restaurants, retail food establishments, and warehouses.
The Food Traceability Rule was mandated by Section 204 of the FDA Food Safety Modernization Act (FSMA), enacted in 2011, which directed FDA to improve tracking and tracing of food through the supply chain. FDA estimated the final rule would cover more than 323,000 domestic businesses operating more than 484,100 establishments. The initial compliance date was set for January 20, 2026, but in March 2025 FDA announced its intention to extend the compliance date by 30 months. In the FY2026 appropriations act, Congress further directed that no funds may be used to administer or enforce the rule prior to July 20, 2028, and directed FDA to provide guidance, engage with stakeholders, and report on its implementation plan.