FDA food traceability: the deadline is 2028, not 2027. What lot codes US buyers will ask for anyway

If you export frozen shrimp, fish, fresh mangoes or fresh herbs to the US, you may have read about a food traceability deadline of 20 January 2026. That date has passed without enforcement, and many blog posts still carry it.

The date that matters now is 20 July 2028. The US Food and Drug Administration (FDA) will not enforce its Food Traceability Rule, often called FSMA 204, before then. The rule itself has not changed.

So 2027 is not a deadline. It is the year your US importer will want to see your lot codes flowing, because its own records start from yours.

Checked against official sources on 28 October 2026.

Why the date moved to 2028

The FDA's Food Traceability Rule page (content current as of 8 October 2026) sets out the history in a few lines.

1. The original compliance date was 20 January 2026.
2. FDA proposed a 30-month extension to 20 July 2028, published in the Federal Register on 7 August 2025.
3. Congress then directed FDA, in the 2026 continuing appropriations act, not to enforce the rule before 20 July 2028.
4. FDA says it intends to comply with that directive.

As far as I could find, the new date rests on the proposal and the Congressional directive. I did not find a final rule fixing it. FDA has also scheduled a virtual public meeting on 6 November 2026 about lot-level tracking and possible flexibilities in how firms comply. Watch the page after that meeting.

Does the rule cover your product?

Only foods on FDA's Food Traceability List are covered, along with foods that contain a listed food in the same form. I read the list (content current as of 24 July 2026) with Indian exports in mind. These entries matter most.

1. Crustaceans, fresh, frozen and previously frozen. FDA names shrimp, crab, lobster and crayfish as examples.
2. Finfish, fresh, frozen and previously frozen, across all species except Siluriformes such as catfish. Smoked finfish is a separate entry.
3. Tropical tree fruits, fresh, including mango, papaya, guava, lychee and jackfruit. Bananas, pineapple and citrus are not included.
4. Fresh herbs, fresh peppers, fresh cucumbers and fresh tomatoes.
5. Soft cheeses, but not those that are frozen or shelf stable at room temperature.

If your product is not on the list and does not contain a listed food in its listed form, this rule does not apply to it. Exemptions also exist, so confirm with your importer before you build anything.

What the rule actually asks for

The rule covers foreign firms as well as American ones. The FDA page says it applies to domestic and foreign firms producing food for US consumption. It asks for four things.

1. A traceability lot code (TLC). FDA defines it as a descriptor, often alphanumeric, that identifies a lot. It is assigned when a firm initially packs a raw agricultural commodity, first receives food from a fishing vessel on land, or transforms a food, for example by processing, repacking or relabelling it.
2. Records of key data elements at critical tracking events such as harvesting, cooling, initial packing, receiving, shipping and transformation.
3. Shipping records. Under 21 CFR 1.1340, the shipper keeps eight data elements for each lot and sends the first seven to the business receiving the food.
4. A sortable electronic spreadsheet given to FDA within 24 hours of a request during an outbreak or recall.

The rule is just as clear on what it does not ask for. The FDA page says nothing about barcodes, GS1 standards or label formats, and calls its spreadsheet template optional.

The code has to travel with the food in the records. How it is printed is left to you and your buyer.

The seven details to send with every shipment

These are the first seven shipping data elements of 21 CFR 1.1340. I would put them on the commercial invoice or packing list as a fixed block, so nobody has to remember them.

The eighth element, the type and number of the reference document, you keep yourself.

The TLC source reference: a field you may already have

The TLC source is the place where the lot code was assigned. The rule lets you give a "TLC source reference" instead of the full address. The US produce industry's PTI guidance on TLC source (12 February 2024) quotes FDA's examples: the FDA Food Facility Registration Number of that place, or a web address that gives FDA the location.

If your plant is registered with FDA as a food facility, that number is one accepted way to fill this field. Check it with your importer, but this one detail may already be sitting in your files.

The case label US produce buyers already use

The rule does not prescribe a label, but the US produce trade settled on one years ago. The Produce Traceability Initiative (PTI) is a voluntary industry programme. Its guidance describes a case label with a GS1-128 barcode and human-readable text, and treats the GTIN plus the batch or lot as the traceability lot code.

PTI is a produce programme. For shrimp, fish or cheese, the buyer's own manual decides. Still, the building blocks are GS1's and work on any carton: a GTIN, a lot and a date, in a GS1-128 barcode. Your GTIN comes from GS1 India, and our lesson on GS1 barcodes in India explains how to get one.

The label also has to survive the trip. A carton of frozen shrimp travels for weeks in a reefer container, and it often sweats when it comes out into warm air. That calls for an adhesive made for frozen surfaces, explained in our lesson on label adhesives. We would also print it by thermal transfer rather than direct thermal.

What to set up in 2027

1. Ask your US importer in writing: is our product on the Food Traceability List, who assigns the TLC, and what format do you want?
2. Fix your lot numbering. One lot per line per shift works for most plants. Keep it to capital letters and digits and within 20 characters, the limit for AI (10). Our lesson on batch traceability shows how to build the records behind it.
3. Agree the TLC format with the buyer. GTIN plus lot is the PTI pattern and a sensible default.
4. Print it on every case, as a GS1-128 barcode with the lot in plain text underneath.
5. Add the seven shipping details as a fixed block on your invoice or packing list.
6. Run a 24-hour drill. Pick one shipped lot and build a sortable spreadsheet of its movements, from raw material to the container. Time yourself.
7. Re-read FDA's page after the 6 November 2026 meeting, and again in mid-2027.

I will be honest about the limit of this lesson, because we are a label maker and not a regulatory consultancy. The rule binds your US customer as much as you, and part of the work happens in its systems, which I cannot see from Jaipur. So when your buyer's written request differs from what I have written here, follow the buyer, and ask why.

Case labels are made by Jagannath Labels, our group's label company. We can print the code. The lot records behind it are yours, and they are the part FDA will ask for.

If your importer has sent you a label specification and you want a second pair of eyes on it, send it through the contact page.

We will read it with you, line by line.