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Inventory & traceability · The complete guide

KDEKey Data Element

In short

Key Data Elements (KDEs) are the specific, named facts the FDA Food Traceability Rule (FSMA 204 — 21 CFR Part 1 Subpart S) requires you to record at each Critical Tracking Event (CTE) for any food on the Food Traceability List (FTL).

Read the full summary

They are not new data — the receiving slip, the packing list, the harvest log already contain most of them — but FSMA 204 standardises exactly which fields, in which structure, with what retention, anchored to a Traceability Lot Code (TLC) that must follow the food across every CTE. The compliance date is 20 January 2026 (after the FDA's January-2025 proposed 30-month extension; confirm current FDA position before any final program decision) and the binding test is operational, not paperwork: when FDA requests records, you must produce them in an electronic, sortable spreadsheet within 24 hours. This page covers what counts as a KDE, the per-CTE KDE schedule (harvesting / cooling / initial packing / first land-based receiver / shipping / receiving / transformation), how the Traceability Lot Code is assigned and carried forward, the format / retention / 24-hour rules, the Traceability Plan that holds it all together, the regulated overlay (Part 1 Subpart S anchors plus the 211/117/507 systems FSMA 204 layers on top of), the KPI suite for KDE programmes, the eight quiet failure modes that turn a KDE programme into a 483 finding, and how V5 Ultimate captures every KDE structurally at the kiosk during normal goods-in / transformation / shipping operations so the 24-hour export is a button, not a project.

3,650 words · ~17 min read
On this page
  1. 01What a KDE is — in one sentence
  2. 02The Traceability Lot Code — the spine that connects KDEs
  3. 03Which KDEs apply at which CTE
  4. 04Format, retention, and the 24-hour rule
  5. 05The Traceability Plan — the document FDA looks for first
  6. 06The regulated overlay — what FSMA 204 layers on top of
  7. 07KDE programme KPIs — what good actually looks like
  8. 08How V5 Ultimate ships KDE capture
  9. 09Eight quiet KDE-programme failures
  10. 10Where FSMA 204 is going
On this page · 10 sections
  1. 1What a KDE is — in one sentence
  2. 2The Traceability Lot Code — the spine that connects KDEs
  3. 3Which KDEs apply at which CTE
  4. 4Format, retention, and the 24-hour rule
  5. 5The Traceability Plan — the document FDA looks for first
  6. 6The regulated overlay — what FSMA 204 layers on top of
  7. 7KDE programme KPIs — what good actually looks like
  8. 8How V5 Ultimate ships KDE capture
  9. 9Eight quiet KDE-programme failures
  10. 10Where FSMA 204 is going
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01What a KDE is — in one sentence

A Key Data Element is a specific, named piece of information that FSMA 204 (21 CFR Part 1 Subpart S) requires you to capture and retain at a specific Critical Tracking Event for any food on the Food Traceability List, structured so that you can hand it to FDA in an electronic, sortable spreadsheet within 24 hours of request.

Three things make KDEs different from the receiving / shipping / production records you already keep:

  1. Named fields. FSMA 204 specifies exactly which fields are required at each CTE — not 'something equivalent', not 'enough to identify the lot'. The field names matter for audit.
  2. Anchored to the Traceability Lot Code (TLC). Every KDE record carries the TLC that links it to its assignment event and to every downstream CTE record for the same food. The TLC is what makes a 24-hour trace possible.
  3. Electronically sortable on 24 hours notice. The records can live in paper, spreadsheets, ERP, WMS, your QMS, or anywhere else — but the legally-binding test is that FDA receives a sortable electronic spreadsheet within 24 hours of asking for it (§1.1455(c)(3)).
Scope reminder

KDEs are only required for foods on the FTL. Soft cheeses, shell eggs, nut butters, fresh-cut produce, fresh herbs, cucumbers, leafy greens, melons, peppers, sprouts, tomatoes, tropical tree fruits, and certain ready-to-eat fish and salads. The FTL is updated periodically; FDA's published list is authoritative. The records you already keep under 117.305 / 507.7 stay in force regardless.

02The Traceability Lot Code — the spine that connects KDEs

The Traceability Lot Code (TLC) is the single most important KDE. It is a unique identifier assigned to a food at one of three trigger events — and from then on the same TLC must travel with every CTE record for that food, all the way to the next transformation.

TLC assignment is triggered by exactly one of:

  • Initial packing of a raw agricultural commodity (other than a food obtained from a fishing vessel) — the packer assigns.
  • First land-based receipt of a food obtained from a fishing vessel — the first land-based receiver assigns.
  • Transformation of a food — the transformer assigns a new TLC for the output(s).

Three KDEs travel with every TLC for the rest of its life: the TLC itself, the TLC source description (location where the TLC was assigned), and the TLC source reference (a unique reference to the location — typically a Location Description that can be tied back to coordinates or a registered facility). A KDE programme that captures TLCs without their source description and source reference is incomplete and will fail a records request.

TLC discipline is the make-or-break decision

The most common cause of a failed FSMA 204 records test is loss of TLC linkage at transformation — the inputs each had a TLC but the operator never recorded which TLCs went into which output TLC. Once that link is broken, the forward trace from inputs and the backward trace from finished product cannot meet, and FDA has 0 records to give downstream firms during a recall.

03Which KDEs apply at which CTE

The seven CTEs each have their own KDE schedule. The table below is the operating summary; the binding text lives in §1.1325–§1.1350.

CTERequired KDEs (operating summary)
Harvesting (§1.1325)Location description of the immediate subsequent recipient (other than a transporter), of the field where the food was harvested, and of the business name and address of the harvester; quantity and unit of measure of the food; date of harvesting.
Cooling — before initial packing (§1.1330)Location description for the immediate subsequent recipient (other than a transporter), the location where the food was cooled, and the harvester / cooler; quantity and unit of measure of the food; date of cooling; date of harvesting.
Initial packing — non-§112 RAC (§1.1335)TLC for the food; quantity and unit of measure; product description; location description of the immediate previous source (harvester / cooler); location of the growing area, of the cooler if cooled, and of the harvester; date of initial packing; reference document type and reference document number; TLC source reference.
First land-based receiver (§1.1340)TLC for the food; quantity and UoM; product description; location description of the immediate previous source (vessel); name of the harvesting vessel, the unique vessel identifier, the trip identifier, and the date of landing; location of the first land-based receiver; reference document type and reference document number; TLC source reference.
Shipping (§1.1345)TLC for the food; quantity and UoM; product description; location description of the immediate subsequent recipient (other than a transporter); location of where the food was shipped from; date shipped; reference document type and reference document number; TLC source reference for each TLC shipped.
Receiving (§1.1345)TLC for the food; quantity and UoM; product description; location description of the immediate previous source (other than a transporter); location where the food was received; date received; reference document type and reference document number; TLC source reference for each TLC received.
Transformation (§1.1350)New TLC(s) assigned to output food(s); TLCs of all inputs and the product description / quantity / UoM for each input used; product description for the output; quantity and UoM of the output; location where transformation was performed; date of completion; reference document type and reference document number.

Two things to notice. First, every CTE except the very first one (harvesting) requires a reference document type and reference document number — typically the bill of lading, the production record, the work order, or the receiving advice. Second, every CTE after TLC assignment requires the TLC source reference, not just the TLC itself; this is the field most often missed by firms that already 'have lot codes'.

04Format, retention, and the 24-hour rule

FSMA 204 is unusually specific about how the records must be kept and produced. The format and retention rules are at §1.1455:

  • Records must be in English (or accompanied by an English translation produced within a reasonable time).
  • Records must be retained for two years from the date of creation.
  • Records must be producible to FDA — on request — in an electronic, sortable spreadsheet format within 24 hours of the request (§1.1455(c)(3)).
  • Original records (paper, electronic, photographic) may be kept in any format; only the response to a records request has the 24-hour electronic-sortable constraint.
  • Records may be stored offsite if they can be retrieved and provided to FDA within 24 hours of request.
  • Hand-written records must be legible and indelibly recorded.
  • Each firm must maintain a written Traceability Plan that describes how records are kept, how TLCs are assigned, which FTL foods are handled, and the point of contact for FDA records requests.
How V5 Ultimate handles it

V5 captures every KDE structurally at the kiosk during normal goods-in / transformation / shipping operations — the operator does not see a separate 'FSMA 204 capture' step, they see the receiving, weighing, dispense or shipping workflow they would normally see, and the KDEs are written behind it. The TLC is assigned automatically using the pattern configured per food type (typically supplier-lot + receipt-date for received foods, work-order-id + completion-date for transformations), carried forward through transformations, and the FDA 24-hour electronic-sortable export is a single button on the Compliance dashboard that produces a CSV/XLSX with one row per CTE record and one column per KDE.

05The Traceability Plan — the document FDA looks for first

§1.1315 requires every covered firm to maintain a written Traceability Plan. Inspectors typically ask for the plan within the first thirty minutes of an inspection; the plan is the document that says 'here is how this firm meets the rule', and the rest of the inspection tests whether actual practice matches it.

A compliant Traceability Plan contains, at minimum:

  1. A description of the procedures used to maintain the records the firm is required to keep under Subpart S, including the format and location of these records.
  2. A description of the procedures used to identify foods on the FTL that the firm manufactures, processes, packs, or holds.
  3. A description of how the firm assigns TLCs to foods, if applicable.
  4. A statement identifying a point of contact for questions regarding the firm's traceability plan and records.
  5. If the firm grows or raises a food on the FTL (other than eggs), a farm map showing the areas where the food is grown or raised, with information sufficient to identify each area, including geographic coordinates.
Update cadence

FSMA 204 requires updates as needed (e.g. when the firm changes how it assigns TLCs, when it adds an FTL food, when the point of contact changes), and requires retention of the previous version for two years after a change. V5 versions the Traceability Plan as a controlled document with effective dates so the audit trail is automatic.

06The regulated overlay — what FSMA 204 layers on top of

FSMA 204 does not replace anything; it sits on top of an existing US food-regulation stack and links to international expectations.

AuthorityClauseWhat it asks for in KDE terms
FDA — FSMA 20421 CFR Part 1 Subpart SThe KDE programme itself: per-CTE KDEs, TLC assignment, 24-hour electronic sortable export, Traceability Plan.
FDA — Preventive Controls (PCQI)21 CFR Part 117 Subpart F (§117.305 records)Underlying records baseline — receiving, monitoring, verification, supplier programmes. KDE capture must not weaken these.
FDA — Preventive Controls for Animal Food21 CFR Part 507Animal-food equivalent records baseline.
FDA — Produce Safety Rule21 CFR Part 112Note: §112 RACs (produce subject to the Produce Safety Rule) have different KDE handling at initial packing — read §1.1335 alongside §112.
FDA — Recall authority21 USC 350lFDA's mandatory recall authority — KDE records are what enable forward + backward trace within FDA's expected response window.
FDA — Reportable Food Registry21 USC 350fWhen a covered firm reports a reportable food, KDE records support immediate identification of affected lots and downstream consignees.
Codex AlimentariusCAC/GL 60-2006 — Principles for TraceabilityInternational alignment — Codex traceability principles match FSMA 204's structural model and are the baseline most trading partners reference.

Two practical points. First, KDE capture does not let you reduce your existing 117.305 records — the FSMA 204 records are additive. Second, KDE records being electronically sortable on 24 hours notice is FSMA 204-specific; the existing PCQI/Produce Safety records have looser format expectations. A firm that meets only the existing records baselines (paper-only, no electronic sort) is non-compliant with FSMA 204 even if it meets every other rule.

07KDE programme KPIs — what good actually looks like

A KDE programme that exists on paper but cannot produce the 24-hour export is the worst of both worlds — full compliance cost, zero compliance value. The KPI suite below is what we monitor for FSMA 204 customers on V5 Ultimate.

KPITargetWhy it matters
24-hour mock-export pass rate100% on monthly drillThe legally-binding test. Run it monthly, not when FDA asks.
TLC linkage completeness at transformation100%Every output TLC has a fully-recorded set of input TLCs. This is the most common break point.
KDE field-completion rate per CTE≥ 99%Per CTE type, per FTL food. Trends below 99% predict the export failing.
Reference document attachment rate≥ 99%Every shipping/receiving/transformation CTE has the BOL / production record / work order attached, not just referenced.
Traceability Plan effective-date currency≤ 12 months since last reviewInspectors weight a current plan; a plan dated 2026-01-15 with no review since is a finding.
FTL identification accuracy100%Every SKU correctly flagged as FTL or non-FTL — the most common cause of missed KDE capture is mis-classified SKUs.
Forward-trace pull-time≤ 5 min from a given input TLC to every downstream CTEOperational test that the data model is healthy, not just complete.
Backward-trace pull-time≤ 5 min from a finished output TLC to every input TLC and supplierRecall-readiness measure that mirrors FDA's expected response.

08How V5 Ultimate ships KDE capture

  1. Per-SKU FTL classification — every item has an explicit ftl: true/false flag (with the FTL category) set at SKU-creation; the kiosk refuses to receive or ship an unflagged SKU into a covered workflow.
  2. TLC pattern per food category — configured at the tenant level (e.g. supplier-lot + ISO-date for received foods, WO-id + completion-timestamp for transformations); the system assigns the TLC automatically at the trigger event so operators cannot forget.
  3. KDE schema enforced per CTE — receiving, shipping, harvesting, cooling, initial packing, first land-based receiver and transformation each have a typed form with all required KDEs as mandatory fields; the workflow cannot complete with a missing KDE.
  4. TLC carry-forward through transformation — when a work order completes, V5 writes every input TLC + product description + quantity to the transformation record alongside the new output TLC, atomically, with an e-signature on the operator and a second on the reviewer per the customer's procedure.
  5. Reference document attachment — every CTE that requires a reference document type + number forces the operator to either attach the document (PDF / image) at capture or reference an already-stored document (BOL, production record, work order).
  6. Traceability Plan as a controlled document — the plan lives in V5 Document Control with effective dates, two-person e-signature on each revision, prior versions retained 2+ years per §1.1455, and the current-effective version downloadable as a single PDF for FDA.
  7. 24-hour electronic sortable export — one button on the Compliance dashboard produces a CSV/XLSX (operator's choice) with one row per CTE record, one column per KDE, sortable by TLC / date / location / CTE type / FTL category; the export carries the V5 Ultimate version stamp + Traceability Plan revision for forensic traceability.
  8. Mock-export scheduler — V5 runs the 24-hour export on a monthly schedule (configurable), verifies that every required KDE is populated, and opens a finding in the Quality module for any missing field; this is the operational test that prevents an inspection surprise.
Mobile-safe at the kiosk

All KDE capture workflows render correctly at ≤390px CSS width on the kiosk — the receiving form on iPhone is the same form on a 24-inch touchscreen, no horizontal scroll, no truncated KDE labels. Per the project standard, we test at 390px before claiming a KDE workflow is shipped.

09Eight quiet KDE-programme failures

  1. TLC not assigned at the trigger event — the food enters the firm with a supplier lot but no TLC, and the supplier lot is then treated as the TLC; this often fails because the supplier's lot rules change without notice.
  2. TLC not carried through transformation — the operator records the inputs and the outputs separately, but never the link between them; the forward + backward trace cannot meet.
  3. Ship-from location confused with supplier address — they are often different (a co-packer ships from one address while invoicing from another); FSMA 204 requires the location of where the food was shipped from.
  4. Reference document number captured but document not retained — the BOL number lives in the system but the BOL itself was thrown out; on records request the firm has the number but not the document.
  5. Mixed FTL and non-FTL foods on the same receipt without differentiation — KDEs captured for the whole pallet rather than per SKU; the FTL line item gets buried.
  6. Records exist but are not electronically sortable within 24 hours — paper logs, three different spreadsheets across three buildings, a folder structure no one has ever exported from; the underlying data is complete but the format test fails.
  7. Traceability Plan stale or missing the farm map — the firm grows an FTL food but never produced the §1.1315(b) farm map with geographic coordinates; this is one of the most common findings on farms.
  8. FTL changes not tracked — FDA updates the FTL but the firm's SKU classification has not been re-reviewed; new FTL foods are being received without KDE capture.

10Where FSMA 204 is going

Two trajectories matter for any KDE programme decision in 2026:

  • FTL expansion. FDA has stated that the current FTL is a starting point. Industry expectation is that the list will expand to additional categories (e.g. seafood beyond the current entries, dairy beyond soft cheeses, fresh produce beyond the current categories) over the next two FTL revision cycles. A KDE programme designed only for the current FTL will need rework; a KDE programme designed as 'capture KDEs for everything, flag the FTL ones for export' will not.
  • The 24-hour electronic-sortable export as de facto baseline. FDA has signalled in public meetings that the format expectation in §1.1455(c)(3) will become the operational baseline for non-FSMA-204 records too — i.e. firms will be expected to produce electronic sortable records on short notice for any FDA records request, not only Subpart S. Designing every receiving / shipping / production record system around 'exportable in CSV/XLSX in minutes' is the correct response.

The customers who will struggle in 2026 are not the ones with paper-only records — those firms know they have to change and are budgeting for it. The hard cases are firms with three or four electronic systems (ERP for receiving, WMS for inventory, MES for production, QMS for quality), where the data is technically electronic but cannot be combined into one sortable spreadsheet in 24 hours. The structural decision is one capture point per CTE — the kiosk on the floor — that writes the KDEs once to a single store. That is the V5 Ultimate model.

Frequently asked questions

Q.Do KDEs apply to every food we make?+

Only to foods on the FDA Food Traceability List (FTL). The current FTL includes soft cheeses, shell eggs, nut butters, fresh-cut produce, fresh herbs, cucumbers, leafy greens, melons, peppers, sprouts, tomatoes, tropical tree fruits, and certain ready-to-eat fish and salads. FDA updates the list periodically — check the FDA FTL page for current scope. Non-FTL foods are not subject to Subpart S, but your existing 117.305 records remain in force.

Q.Is a paper logbook acceptable?+

Yes for original capture — but the legally-binding test at §1.1455(c)(3) is that you can produce the records in an electronic, sortable spreadsheet format within 24 hours of FDA request. A firm with only paper that cannot be converted to a sortable export in that window is non-compliant. Most firms move to structured electronic capture for that reason alone.

Q.What is a Traceability Plan and what has to be in it?+

A short written document required by §1.1315 covering: (a) how the firm maintains its records (format and location); (b) how the firm identifies FTL foods it handles; (c) how the firm assigns TLCs; (d) a named point of contact for FDA records requests; (e) for farms growing an FTL food, a farm map with geographic coordinates of growing areas. The plan must be reviewed and updated when relevant changes occur, with previous versions retained for two years.

Q.When is the compliance date?+

FDA's published compliance date is 20 January 2026. In January 2025 FDA proposed a 30-month extension; confirm the current FDA position before any final program scheduling decision. Most customers are running internal-readiness targets ahead of any official date because the operational changes are real either way.

Q.What's the difference between a TLC and a lot code?+

A lot code is whatever identifier you use internally to group product. A TLC is specifically the FSMA 204 Traceability Lot Code — assigned at one of three trigger events (initial packing of a non-§112 RAC, first land-based receipt of fish, or transformation), carried with the food through every subsequent CTE, and accompanied by a TLC source description and TLC source reference. A TLC can be the same string as your internal lot code, but it must obey the assignment rules and travel with the food.

Q.What happens at transformation — do inputs keep their TLCs?+

The input TLCs do not travel forward on the output as if the food were unchanged — they are recorded as part of the transformation CTE record (which input TLCs were used, in what quantity), and the transformer assigns a new output TLC to the resulting food. Anyone tracing the output back uses the transformation record to reach the inputs; anyone tracing an input forward reaches the transformation record. The link is the transformation record itself, not a continuation of the input TLC.

Q.Does V5 Ultimate replace our ERP or WMS?+

No. V5 sits at the operator-execution layer on the shop floor — that is where the KDEs are generated — and writes the structured KDE records that your ERP and WMS need to reflect downstream. V5 extends your existing ERP / WMS down to the kiosk and closes the FSMA 204 compliance loop. There is no rip-and-replace.

Primary sources

  • 21 CFR Part 1 Subpart S — Additional Traceability Records for Certain Foods (full rule text)
  • FDA — FSMA Final Rule on Requirements for Additional Traceability Records (rule landing page)
  • FDA Food Traceability List (current FTL — soft cheeses, shell eggs, nut butters, fresh-cut produce, fresh herbs, cucumbers, leafy greens, melons, peppers, sprouts, tomatoes, tropical tree fruits, ready-to-eat fish and salads)
  • FDA — Supply Chain Examples for the FSMA Final Rule on Requirements for Additional Traceability Records (worked supply-chain examples)
  • FDA — Traceability Plan and Records FAQ
  • 21 CFR 117.305 — Records subject to the requirements of the Preventive Controls rule (the records baseline FSMA 204 layers on top of)
  • GS1 General Specifications §3.5.5 / §3.6 — Lot, expiry and date Application Identifiers used to carry KDEs in GS1-128 / GS1 DataMatrix

Further reading

  • FSMA 204
    The parent rule that defines the FTL, CTEs, KDEs, TLC and 24-hour export requirement.
  • CTE
    The seven event types where KDEs must be captured — the operational shape of FSMA 204.
  • GS1-128
    The barcode standard that carries the lot + expiry + date KDEs through the supply chain.
  • CoA
    Supplier-side document where many KDEs are first generated; V5 attaches CoAs to the receiving CTE record.
  • Genealogy
    Forward + backward traceability — KDEs + TLCs are the data that makes genealogy executable.
  • HACCP
    Food-safety system FSMA 204 sits alongside; CCP monitoring records and KDE records often share underlying capture.
Software that covers KDE
V5 Ultimate (FSMA 204)
The FDA Food Traceability Final Rule (21 CFR Part 1 Subpart S) requires Key Data Elements at every Critical Tracking Event for…

Explore this topic

KDE sits inside 2 overlapping topic clusters in our glossary. Every neighbour is one click away.

Food safety & GFSI
16 related entries

HACCP, FSMA, allergen control and the GFSI-recognised certification schemes.

HACCPCCPHARPCPCQIFSMA 204CTE21 CFR 117Allergen ControlSSOPTACCP / VACCPGFSISQFBRCGSFSSC 22000ISO 9001MoCRA
Identification, traceability & EDI
13 related entries

GS1 identifiers, barcodes, ASNs and the rules that require lot-level traceability.

GTINSSCCGS1-128UDIEDI 856DSCSAFSMA 204CTEFEFOFIFOISO 13485Supplier risk managementSupply chain risk management
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Where this term comes up
Food ProcessingBakery & ConfectioneryProduce PackingMeat & Sausage
Inside V5
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Related terms
  • → FSMA 204
  • → CTE
  • → HACCP
  • → CCP
  • → HARPC
  • → PCQI
  • → 21 CFR 117
  • → Allergen Control
  • → SSOP
  • → TACCP / VACCP
  • → GFSI
  • → SQF
  • → BRCGS
  • → FSSC 22000
  • → ISO 9001
  • → MoCRA

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