It may feel far off, but the clock is ticking for retailers and suppliers to implement plans to comply with Section 204 of the FDA Food Safety Modernization Act (FSMA). In fact, there were 424 working days left until the deadline (January 20, 2026) when I spoke with Sally Robinson, VP of Strategic Initiatives for Upshop.
It’s a number she keeps handy, she shares, as she’s finding retailers are all at different points in their FSMA 204 journey.
Below, Robinson sheds light on the challenges retailers are facing in meeting FSMA 204 compliance requirements, the multifaceted nature of the issue, and the unique dependencies within the supply chain retailers face.
“Every person in the supply chain is dependent on the person in front of them doing what they need to do before you meet the regulation.”
Jamie Grill-Goodman: Where are retailers at in their paths to FSMA 204 compliance?
Sally Robinson: I think when I speak to retailers, they’re all in different places. Some are much further along than others, and I’m not necessarily convinced that they know exactly what problems they’re going after yet.
Goodman: Have you seen anything in the grocery industry that compares to this?
Robinson: I don’t think there’s anything that crosses across all these areas like this. That’s what makes this unique. It’s multifaceted in terms of supplier readiness. Every person in the supply chain is dependent on the person in front of them doing what they need to do before you meet the regulation. So, because retailers are at the back, all those other folks have to do everything they need to do by January 2026 in order for the retailers to be ready — that cuts that timeline shorter. So, I think that the overall dependency lead can’t just move and solve this in a vacuum.
“The key nuance is, when you transform it into something else, then it gets a new lot code. And that also needs to be tracked.”
Goodman: Regardless, the consumer holds the retailer responsible no matter what happens along the supply chain. With that in mind, what are the top things for retailers to work on for compliance?
Robinson: One is traceability recall and knowing where products went. And the other side is the data component and exchanging all the data elements of that product for high-risk foods.
Goodman: Tell me more about the data component.
Robinson: So, [retailers] are receiving products, they’re shipping products, and — in some cases — they’re transforming products (such as in the deli or with private label products). They will have to capture traceability lot code (TLC), and other attributes across each of the identified high-risk foods. We don’t do this today. Cases have lot codes on them, but we couldn’t necessarily say, ‘well, we took that lot code of strawberries and we made it into this smoothie,” or ‘we shipped it to the supplier, and they took those strawberries and turned them into jam.’
So it’s all of the events where products move throughout the supply chain and transform into something else. And the key nuance is, when you transform it into something else, then it gets a new lot code. And that also needs to be tracked.
It’s the exchange of those data elements throughout the supply chain. It impacts growers, harvesters, packers, and anyone who packs, holds, or ships, foods on the Food Traceability List (FTL).
“Companies are having to capture all that data and exchange it when that product moves throughout the supply chain.”
Goodman: The FDA has already designated foods to the FTL, which is essentially a list for grocers and suppliers of the products for which additional recordkeeping will be required. Is this list finished or do you think they might add to it in the future?
Robinson: If [the FDA] adds to the list, it would be on five-year increments with two years to comply. I mean, that’s how complex it is across the supply chain, when you add a food, to be able to put in the infrastructure to be able to track all the data in this way.
If suppliers are not already pretty far along this journey, they should already be identifying the products that are high risk and thinking about how they’re going to exchange that data with their partners, and how they capture that data within their four walls and share it with others. Same for retailers.
Goodman: Can you give me an example of the complexity of the supply chain in relation to FSMA 204?
Robinson: So, you might have lettuce coming from multiple farms that goes into cooling, and then gets packed into multiple cases and assigned lot codes. Those lot codes go to different processing facilities and are turned into salads and then put into bags.
You can kind of think about the branching elements that happen within the supply chain, and all these companies are having to capture all that data and exchange it when that product moves throughout the supply chain. And the retailer is here wanting to solve the problem, but they’re dependent on how all these companies are doing it.
“I think [retailers] are hoping for the golden ticket where they can just sign up with one provider and they solve all of their FSMA problems.”
Goodman: So how are retailers looking to approach this?
Robinson: I think they’re definitely still assessing. I think they’re hoping for the golden ticket where they can just sign up with one provider and they solve all of their FSMA problems. I think they don’t know how to solve the problem. They’re looking for software providers to solve for them, but they want it to be all inclusive. And I don’t know that that exists quite honestly. There’s a lot of unique use cases.
Goodman: Is there opportunity for grocers to use this to differentiate themselves?
Robinson: I think there’s a future roadmap play here in terms of, once they get their arms around the MVP of what FSMA 204 requires, there’s a lot of crossover into the food safety landscape that is really important and allows you to continually leverage what [the FDA] is trying to get to with some of this legislation, even though it’s a challenging way to go about it,” she says.
There are advancements in barcode technology and how we exchange and comply with data. I think the foodscape safety landscape overall — FSMA is a starting point. I think they’re going to probably expect to be able to trace this even closer to the consumer. So ultimately, it’s going to go further.
And then really the basic premise of this is decreasing instances of foodborne illness and expediting recall and traceability, and the tools we have to quickly remove things from the market.
So if you bring all those pieces together in terms of barcode advancement, capturing things at the front end before they’re sold, knowing when things have expired — I think ultimately, as the technology that helps to exchange the key data points that help identify when things are going to be impacted by foodborne illness, not only does it help the investigation in terms of what caused it in the first place, but you can quickly remove [those items].
And I think being able to expedite that with technology is key, but you can only do it if you have the systems behind it.
