At the 2025 Western Food Safety Conference, Provision Analytics’ Amanda Wilder moderated a panel discussion on the implementation of FSMA 204 traceability.

Panelists

  • kari valdes circle
    Kari Valdés
    Taylor Farms

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  • betsy circle
    Betsy Handelman
    Buyers Edge

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  • eric edmunds circle
    Eric Edmunds
    Partnership for Food Traceability

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  • amanda green circle
    Amanda Wilder
    Provision Analytics


With the FDA now proposing to extend the compliance deadline to July 20 2028, the conversation focused on what this extra time means in practice. Panelists unpacked the most stubborn roadblocks—from inconsistent terminology and fragmented data‑sharing to labor‑intensive scanning—and shared cross‑functional tactics that growers, distributors, and legal counsel are piloting today. Their key message: use the 30‑month grace period to iterate, not to idle, and leave the session with concrete next steps to keep momentum despite the extension.

The Compliance Clock Just Got Reset—But Momentum Shouldn’t

The FDA’s proposal to push the deadline from January 20 2026 to July 20 2028 prompted an instant audience poll: only a handful felt “fully compliant” today. Panelists urged companies not to downshift momentum. The extra runway, they argued, should be treated as a 30‑month sprint: a window to stress‑test data flows, close scanning gaps, and finalize recall playbooks before the stakes rise.

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We’re pausing to re‑evaluate—not stopping. This window lets us pilot solutions and fill data‑sharing gaps before sprinting to the finish line.
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Kari Valdés
Taylor Farms

Attorney Eric Edmunds predicted an “educate‑while‑regulate” posture during inspections, especially if an audit is triggered by an outbreak.

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Five Challenges to Tackle in Your 30‑Month Window

  • Inconsistent terminology
    “Lot,” “batch,” and “PO” are used interchangeably across the chain, breaking record links. Adopt the GS1 glossary and circulate cross‑reference resources so every trading partner speaks the same language.
  • Fragmented data‑sharing expectations
    Some customers request ASNs, others GS1 barcodes, QR codes, or full EPCIS events. Build a matrix of each customer’s EDI/EPCIS requirements and pilot a single EPCIS feed that covers the strictest common denominator.
  • Labor‑intensive scanning
    Case‑level data capture can choke throughput. Shift the burden upstream: print GS1‑128 labels in the pack‑houseand capture SSCCs at pallet level.
  • Disparate systems and siloed decisions
    Software and transportation choices made in isolation create visibility gaps and duplicate spend. Stand up a cross‑functional steering group (IT, Ops, Procurement, Sales, Food Safety) to vet traceability architecture as one enterprise project.
  • Interpreting buyer specifications
    Suppliers still ask, “What exactly do you need, and when?” despite retailers publishing guidelines. Collect each retailer’s latest spec sheet, map required KDEs to your system fields, and run joint mock recalls to expose mismatches early.

Key Takeaways

The 30‑month grace period is a strategic gift—not a reason to coast. Regulators have signaled an “educate‑while‑regulate” mindset, but they’ll still expect to see concrete progress, clean records, and a credible plan of action—especially in the wake of an outbreak. Use the window to pilot ambitious fixes, align systems across departments, and document every lesson learned.

Equally important: tap industry allies. Collaborative groups such as the Partnership for Food Traceability (PFT) are actively harmonizing data formats and sharing pilot results, and they need stronger produce‑sector voices. Joining now helps you shape the standards you’ll later have to meet.

Spending the grace period on disciplined pilots, documented outcomes, and collaborative standards work will turn the July 2028 deadline into a milestone—not a fire drill.