FSMA 204 and 2D barcodes: what the rule does and doesn't require

Updated July 2026

The FDA's Food Traceability Rule under FSMA Section 204 requires businesses handling foods on the Food Traceability List to keep records of Key Data Elements at Critical Tracking Events, and to produce them to FDA within 24 hours on request.

The date

The original compliance date of January 20, 2026 was extended. Following FDA's announced 30-month extension and subsequent congressional direction in the Continuing Appropriations Act of 2026, the operative date is July 20, 2028. The rule itself remains in force; what moved is the enforcement date.

The recordkeeping requirement

The required records include traceability lot codes and the links among receiving, transforming, creating, and shipping events. They must be retrievable in a sortable electronic format within 24 hours.

2D barcodes are not required by FSMA 204. A spreadsheet that meets the recordkeeping and retrieval requirements is compliant. What 2D codes change is how much manual work sits behind that spreadsheet.

Where lot-level codes reduce manual work

• Scanning can capture a traceability lot code without manual transcription.
• A recall can be scoped to specific lots, which is the difference between pulling one production run and pulling a month of product.
• A resolver can direct a scan from an affected lot to customer-approved recall information.
• Some retailers use encoded expiry data for automated markdowns. Confirm that workflow with each receiving system.

Sequencing

Define the records and lot-coding scheme before designing the barcode. Otherwise the encoded data may have to be changed after the traceability workflow is settled.