• On February 19, 2026, the U.S. Food and Drug Administration (FDA) announced multiple actions intended to support implementation of the Food Traceability Rule, a key component of the Food Safety Modernization Act (FSMA). These actions include issuing new guidance to address stakeholder questions, finalizing an exemption for certain cottage cheese products, and initiating a series of stakeholder engagement sessions mandated by Congress.
  • The Food Traceability Rule establishes additional recordkeeping obligations for entities that manufacture, process, pack, or hold foods on the FDA’s Food Traceability List (FTL). These requirements pertain to critical tracking events across the supply chain, such as initial packing, shipping, receiving, and transformation, and are intended to enable faster and more accurate identification of potentially contaminated products during a food safety event. As we’ve previously blogged, there have been numerous logistical challenges for industry in implementing the law due to its complexity, and in August 2025 FDA announced a proposal to extend the compliance date.
  • As part of its February 19 announcement, FDA released a detailed Questions and Answers (Q&A) guidance document to help industry better interpret the rule. The guidance covers applicability to different types of entities, including farms, fishing vessels, retail food establishments, and restaurants, as well as clarification on how specific activities such as intracompany shipments, commingling, or initial packing are treated under the rule. It also provides additional detail on exemptions, such as those for raw molluscan shellfish, and guidance on how to determine whether a product qualifies as “fresh‑cut” for inclusion on the FTL.
  • In addition to issuing guidance, FDA finalized an exemption for certain cottage cheese products, removing them from the scope of the Food Traceability Rule. The agency also announced upcoming stakeholder engagement sessions, which will occur quarterly and are required under recent congressional appropriations legislation. These sessions are intended to provide industry with regular opportunities to engage with FDA, ask implementation‑related questions, and raise practical concerns about compliance.
  • Keller and Heckman will continue to monitor and report on any developments related to the Food Traceability Rule and FSMA.