FSMA 204 for Produce Growers: The Plain-Language Guide

If you grow or pack produce in the United States, you’ve probably heard about FSMA 204. Maybe your buyer mentioned it. Maybe you saw a headline about the FDA. Maybe someone told you that you need “traceability” and you’re not sure what that means in practice.

This guide explains FSMA 204 in plain language. What it is, who it applies to, what you need to do, and what happens if you don’t.

What is FSMA 204?

FSMA 204 is a rule from the FDA — the Food and Drug Administration — that requires additional record-keeping for certain foods. The official name is the “Food Traceability Rule” or “Requirements for Additional Traceability Records for Certain Foods.”

The purpose is simple: when someone gets sick from contaminated food, the FDA wants to be able to trace that food back to where it came from — fast. Not in weeks. In hours.

The rule was finalized in November 2022. Enforcement was originally scheduled for January 2026, but Congress pushed it to July 20, 2028.

Does it apply to me?

It applies to you if you grow, pack, or ship any food on the FDA’s Food Traceability List (FTL). For produce, that includes:

Leafy greens — romaine, spinach, kale, arugula, spring mix, all lettuces
Tomatoes — all fresh varieties
Peppers — bell, hot, sweet, all types
Melons — cantaloupe, honeydew, watermelon
Cucumbers — all fresh varieties
Herbs — cilantro, parsley, basil, all fresh herbs
Sprouts — all types, regardless of seed
Tropical tree fruits — mango, papaya, guava, lychee
Fresh-cut produce — any fruit or vegetable that’s been cut
Green onions — scallions and spring onions

It does NOT apply to you if:

You sell less than $25,000 in produce per year (averaged over 3 years)
You sell only at farmers’ markets or through CSAs (with certain labeling conditions)
You grow produce that’s not on the FTL (like berries or bulb onions — though your buyers may still require traceability)

What do I need to do?

FSMA 204 boils down to four things:

1. Write a Traceability Plan

This is a document that describes:

How you assign lot codes to your produce
What records you keep and where you store them
How you identify the foods you handle
Who someone should contact with questions about your records
If you grow FTL produce: a farm map showing your growing areas

This doesn’t need to be fancy. It needs to be written down and available if the FDA asks.

2. Record Key Data Elements at Critical Tracking Events

This sounds complicated. It’s not.

A Critical Tracking Event (CTE) is a moment in the supply chain where you need to record data. For a grower-packer, there are three:

Growing — when you grow the produce
Initial Packing — when you first pack it into boxes, clamshells, or bags (not field containers)
Shipping — when you send it to a buyer

A Key Data Element (KDE) is a piece of data you record at each CTE. The key ones are:

Data	What it means
Growing area	Where the produce was grown (field name, GPS coordinates)
Commodity and variety	What it is (e.g., “cantaloupe” or “romaine lettuce”)
Harvest date	When it was picked
Traceability Lot Code	A unique code you assign to each lot when you pack it
Quantity	How much (number of pallets, cases, etc.)
Packer info	Your name, address, and phone number
Ship-to info	Where you’re sending it and who’s receiving it
SSCC	A barcode identifier for each pallet
Reference docs	Bill of lading or purchase order number

3. Keep records for 2 years

Every record you create under FSMA 204 must be kept for at least 2 years. Digital records are strongly recommended — if the FDA calls, you need to be able to provide records within 24 hours.

If the FDA requests your traceability records — during a recall, an outbreak investigation, or a routine inspection — you must provide them within 24 hours. For electronic records, this is straightforward. For paper records in file cabinets, this is nearly impossible at scale.

What if I just grow but don’t pack?

If you grow FTL produce but someone else does your packing (a co-packer or a packing house down the road), your requirements are lighter:

Provide your name, address, and phone number to the packer
Provide the commodity, variety, and growing area coordinates
That’s it — the packer handles the rest

But your packer needs this information from you to be compliant. If you don’t provide it, you’re both at risk.

What about my buyers?

Here’s the part that matters right now: your retail buyers aren’t waiting for 2028.

Walmart, Kroger, Albertsons, Target, and Sam’s Club are already requiring traceability data from produce suppliers — many for ALL foods, not just FTL items. Their deadlines have already passed.

Check what your specific buyers require:

Walmart — SSCC-18 and ASN on every pallet
Kroger — traceability for all foods since June 2025
Costco — 2-4 hour recall response expected
See all 35 retailer guides

What are the penalties?

When enforcement begins in July 2028:

Civil fines up to $10,000 per violation per day
Criminal charges possible for willful violations
FDA can suspend your facility registration (effectively shutting you down)
Products can be refused entry at borders (for imports)

But the bigger risk right now is losing your buyers. If Walmart asks for traceability data and you can’t provide it, they don’t wait — they find a grower who can.

How FieldToFile helps

FieldToFile handles the hard parts automatically:

Traceability Lot Codes — assigned automatically when you pack
Key Data Elements — captured at every CTE as part of printing pallet tags
SSCC-18 barcodes — system-generated, zero errors
PTI-compliant labels — print directly to your Zebra from a browser
Partner packing — pack for other growers under their brand
24-hour readiness — export complete records in 30 seconds
2-year retention — digital records, always accessible

No middleware, no desktop installs, no six-month implementation. Open a browser, connect your printer, and start packing.

Evaluating options? See how FieldToFile compares to spreadsheets, ERP systems, and other traceability tools.

Pack a load on us — your first truckload is free, no credit card required.