What Food Businesses Need to Document Between Shipping and Receiving
FSMA 204 requires covered food businesses to connect individual food lots to documented events throughout the supply chain, including shipping and receiving. For refrigerated shipments, that means maintaining traceability even when multiple products or lots travel together in the same truck.
A delivery confirmation can establish that freight arrived. But it may not identify exactly which traceability lots were transferred between facilities. That distinction is central to the FDA’s Food Traceability Rule.
Which Refrigerated Foods Fall Under FSMA 204?
The rule applies to foods on the FDA’s Food Traceability List (FTL), subject to applicable exemptions. Examples include fresh leafy greens, fresh-cut fruits and vegetables, certain cheeses, shell eggs, and seafood products.
Not every refrigerated or frozen food is covered. The applicable requirements depend on the product, its form, and the activities performed by the business.
The Traceability Lot Code Connects Both Ends
The Traceability Lot Code (TLC) identifies a particular food lot and connects it to other required information.
A TLC is generally assigned during initial packing, first land-based receiving of food from a fishing vessel, or transformation. Once assigned, it normally remains unchanged as the food moves through distribution. Shipping alone does not justify creating a new code.
Consider a refrigerated truck carrying three different lots of fresh produce. The transportation order may describe them as one shipment, but the traceability records must preserve the identity of each covered lot.
This distinction matters if one lot later becomes subject to a recall. Accurate records help identify the affected freight without unnecessarily including unrelated products.
What Shipping and Receiving Records Must Contain
For each covered traceability lot, shipping records must identify the TLC, product description, quantity and unit of measure, shipping date, and locations of dispatch and the subsequent recipient.
They must also identify the TLC source (or its reference) and the type and number of the supporting reference document.
The shipping party must provide the required information to the next recipient, excluding the transporter. The receiving business maintains corresponding records, including the actual receipt date and the previous source.
A bill of lading, advance shipping notice, or electronic record can support traceability, provided the required information remains linked to the correct lot. FDA does not require a specific software platform or a single document containing every data element.
Transportation Records and FSMA Records Are Different
A refrigerated shipment may generate GPS data, temperature reports, pickup confirmations, and proof of delivery. These records serve useful operational purposes, but they do not automatically satisfy FSMA 204’s lot-level requirements.
The distinction also affects responsibility.
Under 21 CFR § 1.1305(n), transporters are exempt from the Food Traceability Rule in their capacity as transporters. The applicable recordkeeping obligations generally rest with covered businesses that manufacture, process, pack, or hold listed foods.
However, transportation instructions and shipment documentation should remain consistent with the records maintained by those businesses.
If you’re coordinating refrigerated freight, it helps to establish how lot identifiers, quantities, and collection information will be shared before the shipment moves.
Preparing for the FSMA 204 Timeline
The FDA proposed extending the original January 20, 2026, compliance date to July 20, 2028. Congress subsequently directed the agency not to enforce the Food Traceability Rule before July 20, 2028.
That gives affected businesses additional preparation time. The priority is to make sure food lots remain identifiable across shipping, receiving, and the records connecting them.
Accurate traceability records show where your food shipments have been. Choose Reefer Van Network for refrigerated transportation that keeps freight movements documented and traceable from pickup to delivery.
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