The Safe Food Coalition, comprising key food industry stakeholder groups and consumer protection organizations, has written a letter urging U.S. Congress to reject two bills that would undermine the U.S. Food and Drug Administration’s (FDA’s) Food Traceability Final Rule, fulfilling Subpart 204 of the Food Safety Modernization Act (FSMA 204).
The first piece of legislation, House Resolution (HR) 7563, named the Food Traceability Enhancement Act, would ease recordkeeping and traceability lot code (TLC) requirements for restaurants, retail food establishments, and warehouses by removing the requirement to maintain TLC information and provide such information to supply chain partners or to the Secretary of the U.S. Department of Health and Human Services (the Secretary). Additionally, the legislation would mandate the Secretary to execute at least nine pilot projects to measure the efficacy of foodborne illness outbreak investigations conducted without TLC information, and identify and evaluate low-cost food traceability technologies.
The second piece of legislation—a provision in the fiscal year (FY) 2025 agriculture appropriations bill—aims to put the FDA 2026 implementation date on hold by demanding that the agency conduct additional traceability pilots, including a pilot that will require the agency to “successfully” solve outbreaks without using lot code information. The bill provides no new funding for such pilots and effectively cuts funding the agency at FY 2024 levels. The Safe Food Coalition believes the intent of the appropriation provision is to indefinitely delay the Food Traceability Final Rule by exempting lot code information.
The Safe Food Coalition argues that the Food Traceability Final Rule already aligns with best industry practices. Additionally, as the January 2026 compliance date for FSMA 204 approaches, many companies have made progress in tracking and recording data for food traceability purposes, showing the feasibility of compliance. The stakeholders believe that the proposed exemption of lot code information would “effectively gut” the Food Traceability Final Rule by allowing retailers to discard critical lot code information that has been carefully developed and maintained by companies subject to the rule. These lot codes are crucial to FDA’s ability to trace and solve foodborne illness outbreaks, says the coalition.
Members of the Safe Food Coalition include the Center for Food Safety, the Center for Science in the Public Interest, the Consumer Federation of America, Consumer Reports, Food and Water Watch, the Government Accountability Project, and the National Consumers League.
