How to Check if Your Product is on the FDA Food Traceability List

Why Checking the FTL Matters

The FDA's Food Safety Modernization Act (FSMA) Section 204 rule establishes new traceability recordkeeping requirements for foods on the Food Traceability List. If your product is on the FTL, you must maintain records for specific Critical Tracking Events (CTEs) — such as growing, receiving, transforming, creating, and shipping — along with the corresponding Key Data Elements (KDEs) for each event.

The compliance deadline is January 20, 2026 for most entities, though FDA has indicated enforcement flexibility with a practical enforcement date pushed to July 2028 to give the industry time to build compliant systems. That window is shorter than it sounds. Companies with large product catalogs — hundreds or thousands of SKUs — cannot afford to manually review each item against the FTL the week before the deadline.

Non-compliance carries significant consequences: FDA can issue Warning Letters, pursue injunctions, and in cases of serious violations, pursue criminal charges. More practically, failure to maintain traceability records during a foodborne illness outbreak can make it impossible to quickly identify and recall affected product — putting consumers at risk and your brand in jeopardy.

The FTL is organized by broad food categories, not individual products. Your first task is to identify which of these high-level categories your product plausibly falls into. Do not assume your product is exempt — the FTL covers more ground than most operators initially expect.

Start by answering these questions about your product:

• Is it a fresh, raw, or minimally processed food? (More likely on FTL)
• Is it shelf-stable, canned, dried, or fully cooked? (More likely exempt — but not always)
• Does it contain seafood, fresh produce, or dairy as a primary ingredient?
• Is it a nut butter, fresh-cut vegetable, or ready-to-eat deli item?

These are strong signals that your product may hit the FTL. Even if none of these apply, continue to Steps 2 and 3 — the FTL has categories that catch many operators by surprise.

The FDA Food Traceability List, published as part of the FSMA 204 final rule (21 CFR Part 1, Subpart S), covers the following food categories. Check your product against each one:

Even if your product falls into one of the categories above, it may qualify for an exclusion. The FSMA 204 rule includes explicit exclusions that remove certain product types from FTL obligations. Review these carefully — misapplying an exclusion is a compliance risk, but failing to claim a valid exclusion means unnecessary recordkeeping burden.

If an exclusion applies, document your basis for claiming it. In the event of an FDA inspection, you want a clear paper trail showing why you concluded the FTL did not apply to a given product.

One of the most frequently misunderstood aspects of FSMA 204 is the scope of traceability obligations for multi-ingredient products. The rule is clear: if a food contains an FTL-covered ingredient, the person who first creates that food (the "creator" in FSMA 204 terminology) must maintain traceability records for the creation step.

Consider a prepared chicken Caesar salad sold at retail:

• The romaine lettuce is an FTL food (leafy greens category).
• The chicken is not an FTL food (poultry is not on the FTL).
• The dressing contains no FTL-covered ingredients.

Because the finished product contains romaine lettuce (an FTL food), the entity assembling that salad must maintain traceability records for the creation CTE — specifically the Traceability Lot Code of the romaine used, the quantity received, and the supplier information.

This "contains FTL food" principle is a significant compliance trap for manufacturers of prepared foods, meal kits, catering operations, and food service distributors. You may not sell a single raw FTL-covered product, yet still face recordkeeping obligations because of ingredients you source.

Common Gotchas and Edge Cases

The FTL generates genuine confusion because the line between covered and not-covered sometimes turns on small details — packaging, moisture content, processing method. Here are the most common edge cases with definitive answers:

Programmatic Access via FoodChainAPI

For teams managing large product catalogs or building compliance software, manually checking products one at a time is not feasible. The FoodChainAPI provides programmatic access to FTL classification, enabling you to:

• Batch-check your entire product catalog against the FTL in minutes
• Integrate FTL classification directly into your ERP, WMS, or procurement system
• Automatically flag incoming purchase orders containing FTL-covered items
• Build FSMA 204 compliance features into your food-tech product without maintaining your own FTL data
• Receive the applicable CTE and KDE requirements alongside each classification result

{
  "query": "frozen shrimp",
  "found": true,
  "category": "Crustaceans",
  "matchedFood": "Shrimp (fresh, frozen, live)",
  "confidence": 0.97,
  "excluded": false,
  "ctes": ["Growing/Harvesting", "Receiving", "Shipping"],
  "kdes": [
    "Traceability Lot Code",
    "Quantity and Unit of Measure",
    "Product Description",
    "Location of growing/harvest area",
    "Name and contact of supplier",
    "Date of shipment or receipt"
  ]
}

Next Steps

If you have determined that one or more of your products are on the FTL, your next steps are:

1. Map your CTEs. For each FTL-covered product, identify which Critical Tracking Events occur in your supply chain (growing, receiving, transforming, creating, shipping).
2. Identify required KDEs. Each CTE has specific Key Data Elements you must capture and retain for a minimum of two years.
3. Assess your current systems. Can your existing WMS, ERP, or traceability software capture and link the required KDEs? Many legacy systems cannot — this is the core compliance gap for most operators.
4. Develop a Traceability Plan. FSMA 204 requires covered entities to have a written Traceability Plan describing how you assign, record, and retrieve traceability data.
5. Test your recall capability. Regulators will expect you to produce traceability records within 24 hours of a request during an outbreak investigation. Practice this before you need to do it under pressure.