FDA Food Traceability List (FTL): What Foods Are Covered Under FSMA 204?

By
Molly Goad
March 4, 2026
5 min read
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The Food Traceability List (FTL) is a list of foods identified by the FDA as higher risk for foodborne illness. Under the FSMA 204 traceability rule, companies that manufacture, process, pack, or hold foods on this list must maintain additional traceability records and be able to provide those records to the FDA within 24 hours if requested.

The list is a central part of the Food Safety Modernization Act (FSMA) Section 204 Food Traceability Rule, which requires greater visibility into how certain foods move through the supply chain.

If your organization handles foods on the FTL, you may need to implement new recordkeeping procedures to track where products come from, how they are handled, and where they are shipped.

What Is the Food Traceability List (FTL)?

The Food Traceability List (FTL) identifies foods that the FDA considers more likely to be involved in foodborne illness outbreaks.

These foods require additional traceability records under the FSMA 204 rule, which was designed to improve the FDA’s ability to investigate outbreaks and remove contaminated food from the supply chain quickly.

Companies that manufacture, process, pack, or hold foods on the list must capture specific traceability data at key points in the product lifecycle. These records help regulators trace food back to its origin and identify where contaminated products may have been distributed.

Foods Included on the Food Traceability List

The Food Traceability List includes foods across several categories of the food supply chain. The FDA provides detailed definitions for each category, but the following list highlights the most commonly referenced items.

Produce

Many fresh produce items appear on the Food Traceability List, including:

  • Fresh cucumbers
  • Fresh herbs
  • Fresh leafy greens
  • Fresh peppers
  • Fresh tomatoes
  • Fresh melons
  • Fresh tropical tree fruits
  • Fresh sprouts
  • Fresh-cut fruits and vegetables

These foods are often included because they are consumed raw or minimally processed, which increases the risk of foodborne illness if contamination occurs.

Seafood

Several seafood categories are also included on the Food Traceability List:

  • Finfish
  • Crustaceans
  • Mollusks

Traceability is particularly important in seafood supply chains because products often pass through multiple distributors and processors before reaching retailers or restaurants.

Dairy Products

Certain dairy products appear on the list, including:

  • Cheeses other than hard cheeses

These cheeses may require additional traceability documentation because of how they are produced and stored.

Other Foods

Additional foods covered by the FTL include:

  • Shell eggs
  • Nut butters
  • Ready-to-eat deli salads

These products may involve multiple ingredients or preparation steps, making traceability important during food safety investigations.

What Happens If Your Product Is on the Food Traceability List?

If your company handles foods on the FTL, the FSMA 204 rule requires you to maintain specific traceability records.

These records must capture information at Critical Tracking Events (CTEs) throughout the product lifecycle, such as:

  • Receiving food
  • Transforming food (processing or repackaging)
  • Shipping food to customers

At each of these events, companies must record Key Data Elements (KDEs) that help identify where products originated and where they were sent.

Businesses must also maintain a traceability plan describing how they track foods on the list and how traceability data is captured and stored.

During a food safety investigation, the FDA may request traceability records, and companies must be able to provide those records within 24 hours.

When Must Companies Comply With FSMA 204?

The FDA finalized the Food Traceability Rule in November 2022.

The original compliance deadline was January 2026, but the enforcement timeline has since been extended. Companies that handle foods on the Food Traceability List are now expected to comply with the rule by July 20, 2028.

Although the deadline was extended, many food companies are already updating their systems and procedures to prepare for the new traceability requirements.

How Companies Track Traceability Data

FSMA 204 does not require companies to use a specific technology. However, many organizations are adopting digital systems to help capture and manage traceability records across their supply chains.

Common systems used to support traceability include:

  • Enterprise resource planning (ERP) systems
  • Warehouse management platforms
  • Barcode and lot tracking systems
  • Electronic data exchange tools such as EDI

For example, many retailers and distributors request EDI 856 Advance Ship Notices (ASNs) that include shipment details and product identifiers. These transactions help communicate shipment information electronically and can support traceability efforts across supply chain partners.

Preparing for Food Traceability Requirements

The Food Traceability List plays a central role in determining which businesses must comply with the FSMA 204 Food Traceability Rule. Companies that handle foods on the list must ensure they can capture and retrieve traceability data across the supply chain.

As organizations prepare for these requirements, many are evaluating systems that help manage shipment data, lot tracking, and supply chain communication. Technologies such as ERP systems, barcode tracking tools, and EDI platforms like BOLD VAN can help automate the exchange of shipment information and support traceability visibility across trading partners.

If you’re exploring how electronic data exchange supports traceability, you may also want to read:

Do You Need EDI for FSMA 204 Compliance? How EDI 856 ASNs Enable Food Traceability


Frequently Asked Questions

What is the Food Traceability List?

The Food Traceability List (FTL) identifies foods that require additional traceability records under the FSMA 204 rule. These foods are considered higher risk for foodborne illness and require enhanced tracking throughout the supply chain.

Does FSMA 204 apply to all foods?

No. The rule only applies to foods listed on the FTL, although many companies choose to apply similar traceability practices to all products for consistency.

Who must comply with the Food Traceability Rule?

Companies that manufacture, process, pack, or hold foods on the Food Traceability List must maintain traceability records and follow the requirements of the FSMA 204 rule.

How quickly must traceability records be provided?

If requested by the FDA, companies must typically provide traceability records within 24 hours.

Molly Goad
Content Manager

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