During PDA webinar, leading voices dispel myths and discuss importance of having food traceability plans completed by January 2026.
Two experts on food safety and traceability dispelled myths and discussed the importance of having robust plans in place to meet new Food Safety Modernization Act guidelines during an engaging webinar held Tuesday, Sept. 24, hosted by Alan Siger, President of the Produce Distributors Association (PDA).
The complexities of FSMA 204(d) prompted the session to concentrate on distributors, who are scrambling to both try to understand the nuances of the Food Traceability Final Rule and implement their systems properly in time to meet the January 2026 deadline from the U.S. Food and Drug Administration. The FDA isn’t expected to start conducting routine enforcement until 2027, though both Jennifer McEntire, Ph.D., founder of Food Safety Strategy, and Dave Donat, principal at DRD Produce Consulting, urged distributors to be ready by the starting date.
“This is a big deal. A lot of customers are starting to pay attention to it,” said Donat, who has spent more than three decades helping clients leverage the use of enterprise resource planning software (ERP). “They’re not requiring it per se, but they’re coming out and asking distributors, ‘where are you with FSMA’? It’s the law, and your customers are bugging you to do it. What’s being asked here is doable. So, if you go into it with that mentality, I think you’ll succeed.”
FSMA 204(d) expands the requirements on traceability data-keeping for those who “manufacture, process, pack, or hold foods” on the Food Traceability List (FTL). FDA is aiming to have more streamlined processes in place to react to, and track down, potential contaminants. Distributors must ensure they prepare and trace Key Data Elements (KDE) and Critical Tracking Events (CTE). While the FDA may provide some leeway, McEntire said timing is critical in any potential outbreak or recall.
“The FDA understands that despite giving the industry a little over three years since the rule was finalized, it is still going to take more time for the food community to come together and implement it,” McEntire said. “[But] if FDA requests, each company would need to provide the requested key data elements for the critical tracking events in an electronic, sortable spreadsheet within about 24 hours.”
So, what falls under the Food Traceability List and new FSMA rule? Produce items include fresh cucumbers, tomatoes, sprouts, tropical tree fruits, melons, peppers and leafy greens, plus herbs. Fresh-cut fruits and vegetables, and fresh-cut leafy greens are also on the list. Any other produce items, including table grapes, would not require compliance. However, Donat said distributors might want to consider items they might use in the future.
“If they’ve been cooked, if they have been dried or dehydrated, they come off the list,” McEntire said. “But if they’re fresh – whole, select fresh fruits and vegetables – they are on the list. In addition, any fresh-cut produce item and anything that’s used as an ingredient in another product, like a fresh-cut fruit or vegetable that’s used in a salsa, is also on the list … so that makes it pretty big.”
McEntire and Donat talked in depth about specific situations that require extra attention and took several questions from a full webroom of attendees. Both experts addressed challenges for those trying to meet the new standards, including accounting for missing data and lack of standardized naming. But Donat said creating a plan will be critical to being compliant. He suggested:
- Collecting data about inventory, including product descriptions, lot codes, quantity and unit of measure, location and receiving date.
- Having a method for assigning lot codes.
- Being detailed and organized in data gathering.
- Tracking where everything goes throughout the supply chain.
- Providing data to customers and the FDA when requested.
“You need to be able to provide data [that can be] easily provided to your partners in the supply chain,” Donat said. “It needs to be supplied to the FDA on demand. And you need to have a documented traceability plan – how you are complying with FSMA so that people can understand what you’re doing and why you’re doing it the way you are.”
The FSMA Myths vs. Facts webinar, now online, is one of a multitude or resources available from PDA, which provides support to its members on critical topics that impact the industry.
“If you’re a produce distributor, you belong with us,” Siger said. “We’re the sole voice that speaks just for the produce distributor. Our buying programs, we’ve had members save in excess of $100,000 on purchasing, on credit card processing fees, on packaging supplies. So, it’s more than just acting as a watchdog for our industry. There’s some benefits that can really save you money that goes right to your bottom line”
The PDA, which has expanded greatly since its days as the National Association of Perishable Agriculture Receivers (NAPAR), will again have a prominent presence at the New York Produce Show and Conference, where it will hold its annual meeting on Dec. 10.
“If you’re wondering whether or not to attend a New York Produce Show, you definitely should,” Siger said. “It is a great show, and it’s become more than a regional show. People from all across the country are attending it. It’s a great time to be in New York. We invite all of you to attend and learn a bit a little bit more about what we’re all about.”
About the Produce Distributors Association: Formerly known as the National Association of Perishable Agriculture Receivers (NAPAR), the Produce Distributors Association (PDA) is the national association dedicated to advancing the interests of professionals in the produce distribution industry. With a commitment to excellence, collaboration, and innovation, the PDA provides a platform for networking, education, and advocacy to support the growth and success of its members. For more information about the PDA and membership opportunities, please visit www.producedistributorsassociation.org
