FDA Food Traceability Rule Extended: How Companies Can Approach Compliance Ahead of 2028

March 26, 2026

By George Dyche, VP of Endpoint IC Product Management, Impinj

Key takeaways:

The FDA’s Food Traceability Rule deadline has been extended to July 2028, but companies need to start preparing now.
The food industry is largely unprepared, with most supply chain leaders still relying on slow, manual recall processes.
RAIN RFID technology provides a scalable, real-time solution to help companies meet compliance while also reducing food waste and protecting brand reputation.

As of February 2026, there have been more than 20 reported food and beverage-related recalls in the U.S. In 2025, the total number of recall announcements in the U.S. reached 320, up from 296 in 2024. The food industry has long faced challenges in managing food and beverage recalls and, according to recent research from Impinj, many food supply chain leaders reported their organizations largely rely on manual processes to manage these recalls,potentially slowing down response times, increasing potential for risk, and impacting consumer trust or brand reputation.

First implemented in November 2022, the Food Safety Modernization Act (FSMA) 204 Rule (also known as the FDA Food Traceability Final Rule) establishes traceability recordkeeping requirements for those who manufacture, process, pack, or hold foods included on the Food Traceability List. These products include cheese, nut butter, fruits, herbs, vegetables, and more. The FDA’s Food Traceability Rule was established to enable faster identification and rapid removal of potentially contaminated food as part of widespread efforts to reduce foodborne illnesses and deaths in the U.S.

The FDA recently extended the compliance deadline to July 20, 2028, a 30-month extension.

Why was the FDA’s compliance deadline extended?

According to the FDA, the 2028 extension “affords covered entities the additional time necessary to ensure complete coordination across the supply chain in order to fully implement the final rule’s requirements.” Further, the FDA reported that those who were well-positioned to comply with the final rule expressed concern regarding the timeline, noting their “reliance on receiving accurate data from their supply chain partners, who are not similarly situated.”

For food supply chain leaders, the FDA’s extension offers three opportunities:

To modernize their supply chains to both meet the 2028 deadline and witness benefits beyond compliance
To strengthen food safety and food recall response
To protect consumer trust for the long term

How prepared is the food industry to meet compliance?

According to a 2025 survey of U.S. food supply chain professionals, 59% are concerned about meeting the FDA’s upcoming Food Traceability Rule, and 36% believe they won’t make the extension deadline. This also raises concerns among U.S. consumers, an overwhelming 63% who said they are likely to stop buying a specific product or from a brand in the event of a widespread recall or food safety issue.

The same survey of supply chain professionals found that, among the top issues faced when it comes to addressing food recalls, include difficulty tracing affected batches across locations (42%), manual processes and limited automation (33%), lack of real-time inventory visibility (33%) and incomplete or inaccurate product data (30%).

With just two years to go until the new compliance date for the FDA’s rule, impacted groups will need to act now to ensure that they are able to meet the approaching deadline.

Technology’s role in enabling compliance with the FDA’s rule

Among requirements under the rule is establishing and maintaining a traceability plan that describes procedures for maintenance of records, identification of Food Traceability List (FTL) foods handled, and assignment of traceability lot codes to FTL foods. Impacted groups will need to maintain and provide their supply chain partners with key data elements (KDEs) for certain critical tracking events (CTEs) in the food supply chain. According to the FDA, this “forms the foundation for effective and efficient tracing and clearly communicates the information that FDA needs to perform such tracing.”

With the right food traceability solution, food suppliers and manufacturers can support compliance efforts with the FDA’s rule while also strengthening and modernizing their supply chains for the long term. RAIN RFID, a passive, battery-free wireless traceability technology that enables businesses to seamlessly identify, locate, authenticate, and engage with every tagged item, is emerging as a key component of scalable food traceability solutions. RFID tags provide unique identifiers for individual items, with key item data recorded in databases and updated in near real-time.

These include everything from expiration dates, information on product origin, batch and lot numbers, and more. This information can enable grocers to manage inventory more efficiently and prioritize sales based on shelf life. And in the instance of a recall, products that are associated with a specific batch or lot number can be quickly identified and removed from shelves. When it comes to monitoring fruits and vegetables, both of which are included on the FDA’s FTL, RAIN RFID can also be used to track data about growing conditions, including humidity, temperature, and soil chemistry.

Deploying the right food traceability solution is the first step to ensure companies can provide all the information required under the Food Traceability Rule ahead of the 2028 deadline. RAIN RFID not only delivers food suppliers and manufacturers the critical data they need to comply with regulations like the FDA’s rule, but that data can also be instrumental in helping food retailers reduce food waste and enhance supply chain integrity, ultimately securing consumer trust and brand reputation.

George leads Impinj’s Product Management team for its market-leading endpoint integrated circuit (IC) portfolio. He brings over 28 years of experience leading global teams and developing successful product strategies delivering global adoption of RAIN RFID technology and wireless point-to-point microwave radio systems. He joined Impinj in November 2024.