• On June 10, 2026, the U.S. Food and Drug Administration (FDA) released a report on the Traceability Readiness Tabletop Exercises held with industry between March 9 and April 1, 2026.  The report was released in anticipation of a public meeting on June 15, 2026, where FDA will engage with stakeholders regarding the lot-level tracking requirements in the Food Traceability Rule (FTR).
  • The exercises were developed to help companies prepare to comply with the FTR, which requires manufacturers that process, pack, or hold foods included on the Food Traceability List (FTL) to maintain records containing Key Data Elements (KDEs) associated with specific Critical Tracking Events (CTEs), which are used to track critical events in the food’s supply chain.  In the exercise, participating companies had to respond to a mock FDA request by providing traceability records within 24 hours and if available, a traceability plan.
  • The report highlighted that while there was meaningful progress toward meeting the FTR requirements, there were still some significant gaps in information retention and sharing.  For example, the report noted that although most companies responded within 24 hours, they showed uneven readiness in sharing Traceability Lot Codes (TLC) and TLC source information, and that data quality and completeness require attention across all CTEs a firm performs.
  • In addition to the report, FDA updated its frequently asked questions on the FTR to provide greater guidance on different topics such as food traceability plans and intracompany shipments.
  • Keller and Heckman will continue to monitor and report on developments involving the FTR.