As restaurant operators, food safety is always of the utmost concern. Designed to keep the food supply safe by quickly identifying and removing potentially contaminated foods, The Food and Drug Administration (FDA’s) released the Food Traceability Rule in November 2022. The Rule, which establishes new record keeping requirements for food handlers and producers, goes into effect in 2026.
While that might seem like the distant future, because it will completely alter the way food operators track and record ingredients, the FDA suggests that restaurants start preparing now.
What This Means For Restaurants
Beginning on January 20, 2026, restaurants will be required to follow a new set of food traceability rules to track food items on the FDA’s Food Traceability List.
On the List are food products such as fresh fruit, vegetables, eggs, nut butters, cheese, and seafood products, and restaurants will need to keep a digital record of their origination.
Suppliers and restaurants will need to work together to establish information exchanges that will indicate where a product originated, the date and location a product was accepted, traceability lot-code source information, and reference document information.
Restaurants will be required to develop an electronic traceability plan that describes their procedure for maintaining records for all of the foods on the list that they handle. If there is a food-related outbreak, a restaurant will be required to present the traceability records to the FDA within 24 hours.
Any restaurant that sells food and beverages totaling more than $250,000 annually will be required to comply with the rule.
While the new rule is expected to be quite beneficial in keeping consumers safe, the additional record-keeping requirements are also expected to result in increased costs to restaurants, ultimately impacting profit margins.
How Restaurants Can Prepare for the Food Traceability Rule
As the Food Traceability Rule compliance date approaches, restaurants should begin taking steps to prepare.
Restaurant owners and managers should read and make sure they thoroughly understand the rule, how it applies to their business, and whether any exemptions apply.
Food service businesses should assess their existing data management systems to determine what information they currently possess and receive from their suppliers and what changes will need to be made.
Restaurants must initiate discussions with their suppliers to ensure there is a mutual understanding of compliance requirements.
The ability to trace foods across the supply chain is important for a number of reasons.
1. It protects the consumers' health by identifying recipients of foods that may be unsafe in a timely and efficient manner, allowing for rapid recalls and warnings.
2. Secondly, the ability to identify and remove unsafe food from the supply chain, off of restaurant menus, and out of consumers' mouths quickly can help minimize liability if a food safety event should occur.
3. Additionally, enhanced food traceability can help anticipate disruptions in the food supply chain.
4. Finally, being able to identify the source of a foodborne outbreak or contamination can also help prevent producers from being unfairly impacted by events that have nothing to do with them. Recently, an outbreak related to romaine lettuce, for example, forced the product to be removed from store shelves. Because the supply source was not quickly identified, it negatively impacted all suppliers, even those that were completely safe.
Big 6 Pathogens
According to the CDC, 250 foodborne pathogens are the cause of an alarming 48 million illnesses in the US every year. Of that 250, six have been identified as being the predominant sources of outbreaks across the country every year. It's important for all food handlers to become aware of these pathogens so they can properly address and prevent them from harming your customers and negatively impacting your business.
FoodDocs, developers of AI-powered food safety-compliance software, has created a 100% free and downloadable Big 6 Pathogens Poster that you can print and display in your kitchen. Not only does the poster identify these harmful pathogens, but it is a great source for your staff, listing preventative measures they can take to avoid problems.Once printed and displayed, it is important to review it with current employees and make awareness a part of your onboarding process.
The FDA’s Final Food Traceability Rule is the first step to achieving end-to-end traceability throughout the supply chain. While many food-related businesses have already established tracing systems, they are not yet standardized. The new Rule will allow the various players in the food system to speak the same language.
Though three years may seem like a long time to prepare for compliance, there are many moving parts. As such, it will take time for restaurants to understand, implement, and apply the rule, and educate and train staff before it goes into effect. Restaurants will not only have to figure out which of their foods and thousands of SKUs are on the “list” but they must also be able to determine how to deal with ingredients that are transformed as it moves along the supply chain.
Because the rule is complicated, the FDA offers a great deal of user-friendly materials on its website, including an interactive tool for determining whether an exemption applies. Additional materials needed to better understand how the rule applies in particular situations are still in the development stage.
The agency is vowing to provide additional information, educational tools, and technological assistance as needed during the next three years to help make for a seamless transition.
By Eileen Strauss
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