What is the FSMA 204 compliance date now?

How it got there

• Nov 2022The Food Traceability Final Rule is published in the Federal Register.
• Jan 20, 2026The original compliance date.
• Mar 2025FDA announces its intention to extend the date by 30 months.
• Aug 7, 2025FDA publishes the proposed extension in the Federal Register.
• Nov 2025Congress directs FDA not to enforce the rule before July 20, 2028.
• Jul 20, 2028The federal compliance date as it stands today.

The rule did not change — only the date

Nothing about what you have to record was softened. Traceability lot codes, key data elements at every critical tracking event, a written traceability plan, and the ability to hand FDA a sortable electronic file within 24 hours are all still exactly as written. The extension bought coordination time across the supply chain, not relief from the requirements.

Why 2028 is probably not your real deadline

Large retail buyers set their own traceability requirements and did not wait for FDA. Walmart’s supplier traceability requirement took effect in August 2025, and non-compliant shipments have been drawing chargebacks since. If you sell into mass retail, the commercial deadline arrived before the regulatory one, and it comes with an invoice attached.

What to do with the time

• Get lot code assignment right first — at initial packing, first land-based receiver, and transformation. Everything downstream inherits those codes.
• Fix receiving. Linking a supplier’s lot code to your own record is where most chains break.
• Test the 24-hour requirement before someone else does. If you cannot export a sortable file today, that is the project.
• Ask your three largest customers what they require and when. That answer usually resets the timeline.

Verify the current date against FDA’s Food Traceability Final Rule page before relying on it. Educational information, not legal advice.