Mock Recalls, Real Gains: How Stress-Testing Traceability Can Ensure FSMA 204 Readiness

FSMA 204, the FDA’s Food Traceability Final Rule, remains a pressing priority despite a recent 30-month compliance delay. Originally set for January 2026, the deadline is now mid-2028 – yet the rule’s requirements haven’t changed. In fact, experts warn that this grace period could raise the bar: according to The Packer, experts feel that the extension will mean a lower tolerance for those who cannot deliver the required information promptly.

The mandate still calls for end-to-end tracking of foods on the FDA’s Traceability List, with companies expected to capture Key Data Elements (KDEs) for critical events and, if needed, furnish them to FDA within 24 hours in a sortable electronic spreadsheet. The goal is a big leap in food safety, slashing outbreak investigation times from weeks to days. In short, even though the finish line moved, the race to robust traceability is very much on – and early movers will be far better prepared to cross it successfully.

Published in the April/May 2025 issue of Food Safety Magazine, readers were offered a peek into Taylor Farms’ FSMA 204 preparations. In the article, Drew McDonald (Taylor Farms’ SVP of Quality & Food Safety) discussed how his team is already taking active steps to stress-test their traceability systems ahead of FSMA 204. One of North America’s largest produce suppliers, Taylor Farms hasn’t treated traceability as just a compliance box to tick. Instead, they see it as a tool for operational excellence.

McDonald noted in the article that many companies limit testing to simple mock recalls, but that’s only a starting point. True readiness means going further: “work through real-world, complex scenarios” rather than just basic drills. Taylor Farms developed challenging test exercises to uncover weaknesses. For example, one scenario involved tracing two weeks’ worth of shipments from a month ago for multiple products sharing ingredients, then identifying everywhere those products went and which other products used the same ingredients – all compiled in a sortable spreadsheet.

In essence, they simulate the kind of multifaceted traceback request that regulators or customers might throw at a company. The company even looped in some of its suppliers and customers during these exercises, yielding “very useful learnings” across the supply chain. This proactive, inclusive approach has become an industry case study in FSMA 204 readiness. It demonstrates that robust traceability isn’t achieved by paper compliance alone; it’s earned through practice and continuous improvement.

Go Beyond the Basic Mock Recall

Design realistic, complex trace-back scenarios that mirror actual challenges. Rather than tracing a single product in a vacuum, mix things up. For instance, test if you could quickly pull records for several different items that share common ingredients or lot inputs over a past time window. Simulate a regulator’s request: Can your team identify all shipments of Product X in the last month, plus any other products that used the same batch of Ingredient Y, along with where everything went? Pushing the limits of your data in this way will reveal whether your current record-keeping can handle FSMA 204’s complexity. As Taylor Farms found, these scenario drills expose gaps that a simple one-product mock recall might miss.
Involve Cross-Functional Teams - and Your Suppliers

Don’t keep drills inside the quality office. Pull in IT, operations, and your upstream growers or co-packers so the exercise mirrors real product flow from field to DC to customer. Before the drill, confirm each supplier can push lot details in a lightweight Advance Ship Notice (ASN) or EPCIS event message; both formats pass the same key data in a machine-readable way. Swapping a sample ASN/EPCIS file during practice surfaces gaps early and trains every link in the chain for a true 24-hour traceback.
Evaluate Data Readiness and Speed

Finally, assess how quickly and accurately you can compile the required information when under pressure. FSMA 204 effectively requires an “audit-ready” data system – you should be able to pull all pertinent KDEs for an item (or group of items) and output them in a clean, GS1-compliant CSV or Excel file on short notice. After each drill, ask: Could we produce the FDA’s requested 24-hour traceback report easily?

If gathering the data was a scramble—digging through paper logs or manually merging spreadsheets—identify where to streamline. The more you practice now, the faster and more confidently your team can respond when it counts. Treat each gap found as an opportunity to improve procedures, update forms, or train staff so that real events won’t catch you off guard.

Mobile Barcode Scanning

Replacing pen‑and‑paper with camera‑enabled scanning - like Provision’s in-device barcode capture - lets operators capture GTINs, lot codes, and dates in seconds, eliminating transcription errors and shrinking data‑entry time.
Operator Guidance & Digital Workflows

Tablet or phone apps walk staff through required KDEs step‑by‑step. Missing fields trigger on‑screen prompts, preventing a batch from moving forward until all traceability data is complete.
Data Integration & Standardized Outputs

Linking traceability tools to enable automation saves time, while one‑click GS1‑compliant, EPCIS-enabled exports and ASNs push clean lot data downstream to customers and regulators.

FSMA 204 may be a regulation, but it can also be a catalyst for positive change. Companies that treat these next few years as an opportunity to level-up traceability will find themselves a step ahead of the pack. By conducting early drills and investing in the right processes and tools, businesses not only ensure they’ll meet the rule when enforcement hits, but also gain a reputation for transparency and responsiveness. In an era of frequent recalls and keen consumer awareness, that is a real competitive advantage.

Top retailers and foodservice buyers are already signaling that they expect enhanced traceability from their suppliers – in many cases, for all products, not just those on the FDA’s list. Being able to readily provide complete, verified trace-back info can make you a preferred partner (and conversely, lacking that capability could become a deal-breaker). Moreover, fine-tuning traceability now has internal payoffs: tighter inventory control, more efficient audits, and confidence in your crisis response playbook. The bottom line is that the extended deadline is not a time to hit snooze - it’s a chance to train hard and iron out kinks, so that by the time 2028 arrives, you’re not scrambling – you’re striding confidently, having turned traceability into both a compliance success and a business strength.