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21 CFR 1 Subpart S

Requirements for Additional Traceability Records for Certain Foods · fsma 204 · food traceability rule · fstr · subpart s · 21 cfr 1 subpart s · 21 cfr 1 subpart l

In short

FSMA Section 204 — the Food Traceability Rule. Anyone who manufactures, processes, packs, or holds a Food Traceability List item must keep Key Data Elements for Critical Tracking Events and make them available to FDA within 24 hours or an agreed time; FDA will not enforce before 20 July 2028.

21 CFR Part 1 Subpart S implements Section 204 of FSMA. (Subpart L is the separate Foreign Supplier Verification Programs rule.) It applies to any person who manufactures, processes, packs, or holds foods on the Food Traceability List (FTL) — leafy greens, fresh-cut fruits and vegetables, sprouts, melons, fresh herbs, fresh tropical fruits, shell eggs, nut butters, fresh and frozen finfish and crustaceans, ready-to-eat deli salads, soft and semi-soft cheese, and others. For each Critical Tracking Event (CTE) — harvesting, cooling, initial packing, shipping, receiving, transformation — the firm must capture defined Key Data Elements (KDEs) including the Traceability Lot Code (TLC), reference document identifiers, dates, quantities, and location identifiers (in many cases including geo-coordinates).

Records must be kept for two years as original paper or electronic records or true copies (21 CFR 1.1455), and made available to FDA within 24 hours of a request or within a reasonable time FDA agrees to. In outbreak, recall or other public-health situations, FDA can require certain information as an electronic sortable spreadsheet, with exemptions for some smaller entities. FDA has proposed extending the compliance date from 20 January 2026 to 20 July 2028, and Congress has directed FDA not to enforce the rule before 20 July 2028. Importers of FTL foods are also covered; foreign supplier verification is the separate Subpart L.

Regulatory anchors
  • 21 CFR Part 1 Subpart S
  • 21 CFR 1.1305
  • 21 CFR 1.1310
Where this term comes up
Food ProcessingBakery & ConfectioneryIngredients & Dry MixesProduce PackingMeat & Sausage
How V5 handles it
Food safety — one regulated backbone from HACCP plan to mock recall.
V5's Food Safety stack is purpose-built for food, bakery and supplement plants under FSMA 117, BRCGS, SQF and FDA / EU / UK / Canada / FSANZ labelling. HACCP plan, live CCP monitoring, allergen run-order, glass & brittle plastic register, master sanitation schedule, timed mock recalls, plus bakery-specific operations — bulk silos, sourdough starters, par-baked handoffs, rest & proof timers, country labels with live Nutrition Facts preview, retailer spec versioning with diff, waste-to-feed with allergen-safe gate, and a realtime crew board.
Score your compliance gap — then download the validation pack.
A guided self-assessment walks you against the regulator clauses that apply to your industry. The validation pack — IQ/OQ scripts, traceability matrix, risk assessment, intended-use statement — generates from the same evidence so you can hand it to an auditor on day one.
Related terms
FSMA 204HACCPFSVPParent Lot Child Lot
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