Traceability Secrets for Resilient Supply Chains
A Guide to Harnessing F&B Data
Introduction
Why the traceability era redefines food safety
Few food safety regulations have generated as much conversation—and anxiety—as the Food Safety Modernization Act (FSMA) Rule for Traceability, commonly known as FSMA 204. Its intent is far-reaching: not to ensnare companies in bureaucracy, but to provide industry and regulators with the digital visibility needed to act faster, protect consumers, and future-proof the food system.
To navigate this new era, companies need more than regulatory understanding; they need insider insight and actionable strategies.
This guide is the product of a strategic collaboration between TraceGains and iFoodDS, two leaders at the forefront of food supply chain innovation. It draws on the expertise of Andy Kennedy, co-author of FSMA 204 and Chief Traceability Officer at iFoodDS, alongside Natalie Hunter of New Era Partners, iFoodDS’s consulting arm. Together, they offer an insider’s view into the traceability era, revealing six traceability “secrets” that most companies are only beginning to realize: how transparency, interoperability, and collaboration will determine who thrives and who falls behind.
Contributors:
Andy Kennedy
Chief Traceability Officer
iFoodDS
Andy Kennedy is a leading expert in food safety and traceability, instrumental in shaping the FDA Food Traceability Rule as part of the New Era of Smarter Food Safety initiative. He co-chaired the Technology Working Group for the Produce Traceability Initiative and the GS1 EPCIS/CBV 1.2 MSWG, advancing industry traceability standards. Today, Andy helps food companies navigate FSMA Rule 204, using data to build safer, more transparent, and resilient supply chains.
Natalie Hunter
Managing Director
New Era Partners
Natalie Hunter is an expert in sustainable supply chains, traceability technology, and business development. At the Marine Stewardship Council, she advanced global standards for sustainable fishing under the UN framework. Now at New Era Partners, she helps companies leverage traceability technology to drive efficiency, transparency, and sustainability.
Secret #1
The great convergence will decide who consumers trust
Even before regulatory mandates took shape, consumers were signaling their expectations. Traceability has now fused with these demands, creating a new imperative: brands must demonstrably uphold safety, sustainability, and sourcing integrity, or risk eroding both consumer trust and their place on the shelf.
Research from The Power of Brand Transparency in CPG Food Brands shows the shift is undeniable:
%
of shoppers say transparency is “extremely important” or “important” when choosing brands.
%
of those who prioritize transparency, 86% also value traceability, linking the two as inseparable.
%
of U.S. consumers now want the story behind their food — where it comes from, how it was made, and whether it aligns with their values.
At the same time, regulators and retailers are formalizing those expectations into hard requirements for traceability and disclosure. This great convergence—where consumer demand, regulatory oversight, and retail expectations intersect—makes transparency and traceability inseparable (and non-negotiable). Companies that can deliver trustworthy, digitized supply chain stories will have a clear advantage on crowded shelves and in competitive supplier negotiations.
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“We’re seeing a convergence across sustainability and food safety, but also consumer awareness of the food that they’re eating. Consumers want more information and there's a big push for better communication. Retailers are realizing that a connected supply chain and communicating with consumers through digitized point of sale, that’s the future.”—Andy Kennedy, Chief Traceability Officer at iFoodDS
This is where transparency and traceability often get blurred. While they’re related, they’re not the same thing. Transparency is about what you choose to reveal to consumers and partners. Traceability is the data foundation that allows for effective outbreak response in the event of a food safety issue.
Balancing effective incident response with the legitimate needs of brands and suppliers to protect proprietary supply chain data is an important aspect of building an effective food safety strategy for the future.
"There is a difference between transparency and traceability, though we generally use them as synonyms. Traceability can provide transparency, but it doesn’t necessarily have to provide a fully open door, especially when you digitize things."—Natalie Hunter, Managing Director at New Era Partners
Consider this your inside track
Consumer expectations are already outpacing regulation, and FSMA 204 is the framework that allows brands to rise to the challenge.
Those who digitize traceability will not only validate their claims and safeguard reputation, but also earn lasting loyalty in a market where trust is the true currency. At the same time, robust digital protections ensure that transparency can coexist with confidentiality—empowering companies to share what matters with regulators while protecting the data that defines their competitive edge.
Secret #2
FSMA 204 is a data goldmine
When the FDA extended the FSMA 204 compliance deadline to July 20, 2028, many food companies breathed a sigh of relief. More time. Less pressure. But here’s the truth: the clock is still ticking and those who wait risk missing out on one of the most valuable business opportunities FSMA 204 provides.
What looks like regulatory obligation is, in reality, a goldmine of supply chain intelligence—and FSMA 204 compels companies to claim it. For the first time, companies are required to consistently track Key Data Elements (KDEs) across Critical Tracking Events (CTEs).
CTEs
CTEs are the major points in the food supply chain where risks tend to be concentrated—things like harvesting, cooling, packing, shipping, and receiving.
KDEs
KDEs are the details attached to those events—lot codes, quantities, dates, locations, and supplier information.
Together, they form a digital breadcrumb trail of where food came from, where it went, and how it was handled along the way.
"This is not designed as a ‘gotcha’ program. The endpoint of this rule is that electronic sortable spreadsheet and the FDA has published a template listing all the CTEs and KDEs. Drilling in on those and figuring out ways to share them with your trading partner, receive them from suppliers, and send them to the FDA — that’s where the rubber meets the road right now."—Andy Kennedy, Chief Traceability Officer at iFoodDS
The spreadsheet is the compliance output. But the value lies in the data itself. Capturing KDEs across your supply chain provides visibility you’ve never had before:
- Which suppliers consistently deliver on time.
- Where waste and yield loss are occurring.
- How logistics partners impact quality.
- What vulnerabilities exist in sourcing or labeling.
These insights don’t just satisfy regulators—they improve margins, build resilience, and unlock competitive advantage.
"Traceability at its core is just about data. It enables you to understand where your products come from and how they’re handled. This collection of data provides businesses with a lot of power and insight into their own operations and supply chains that they wouldn’t have without it."
—Natalie Hunter, Managing Director at New Era Partners
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Consider this your inside track
FSMA 204 is not just a regulatory requirement. It’s an opportunity for brands and suppliers to unlock key insights into their own operations.
Companies that see beyond the spreadsheet will be the ones that outpace competitors, win retailer trust, and secure consumer loyalty in the years ahead.
Secret #3
Interoperability is the hidden battleground
If FSMA 204 has a hidden twist, it’s this: compliance doesn’t live in a vacuum. Traceability isn’t achieved by one player alone. Every handoff—every Critical Tracking Event (CTE) across farms, processors, distributors, and retailers — creates a data exchange. The challenge isn’t just capturing those Key Data Elements (KDEs), it’s making sure the information can actually move, connect, and remain usable across an entire ecosystem of players.
That’s where the battle is brewing. Companies may be able to build strong internal traceability systems, but the real competitive advantage lies in how well those systems talk to others.
Proprietary spreadsheets, siloed databases, or one-off portals create digital choke points. And when those bottlenecks stack up across a supply chain, speed, visibility, and compliance all collapse.
The FDA’s design of FSMA 204 implicitly acknowledges this. By mandating structured KDEs at each CTE, the rule nudges companies toward data standardization. That creates the foundation for interoperability, but it’s still up to industry to take the next step.
“Interoperability is a hot topic—how is information shared between participants in the supply chain, and how is information conveyed to FDA when they request an electronic sortable spreadsheet? Working out those little technical details takes time and especially up and down the food supply chain because technologies vary from point to point. So doing those initial pilots and getting started with testing your shipping and receiving records, testing master data sharing, testing how is that lot code going to be shared with your trading partner? How is the lot code source going to be shared? A lot of that is not widely collected."
—Andy Kennedy, Chief Traceability Officer, iFoodDS
Companies that pilot now—testing shipping and receiving records, lot code sharing, and master data exchange with trading partners—will be the ones best positioned for compliance and collaboration.
Consider this your inside track
Interoperability is the proving ground of the traceability era.
Get it right, and you’ll move faster than regulators and competitors alike. Ignore it, and you’ll be locked out of the networks shaping tomorrow’s supply chain.
Secret #4
AI is the traceability breakthrough
One of the biggest barriers to FSMA 204 compliance isn’t the regulation itself—it’s the paperwork. For decades, supplier documentation has flowed in as PDFs, emails, spreadsheets, and even scanned images, leaving food companies with mountains of unstructured data. Every KDE required under FSMA 204 already exists somewhere in that pile. The problem has been how to capture it.
That’s where AI-driven data extraction is a game-changer. By automatically pulling KDEs from supplier documents and linking them to the right CTEs, AI eliminates the endless hours of manual data entry that used to bog down compliance teams. Instead of clerks keying in lot codes, allergens, and harvest dates, an AI engine can capture, validate, and store it in structured form—ready for both operational use and FDA submission.
The benefit goes beyond reducing administrative burden. Automated ingestion makes traceability faster, more accurate, and more scalable. It gives companies confidence that when the FDA asks for an electronic sortable spreadsheet, the data is already organized and export-ready. That’s true enforcement resilience, not scrambling under pressure.
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"With an [AI] agent, you can do fine-grain anomaly detection using trend analysis and comparison year over year. You can do much more deduction and error detection in your supply chain. The power of all this data collection will enable you to ask questions and do things which you really were not able to do economically before."
— Andy Kennedy, Chief Traceability Officer, iFoodDS
And the upside doesn’t stop at compliance. AI turns traceability into business intelligence. Once KDEs are captured consistently, they unlock higher-order insights: trend detection, anomaly spotting, and predictive risk management. AI shifts traceability from a cost center to a strategic capability.
Consider this your inside track
AI is the breakthrough that turns traceability into an engine of intelligence, unlocking smarter, faster decisions across your supply chain.
Secret #5
Traceability unlocks new value streams
If FSMA 204 feels big, it’s only the beginning. The traceability era isn’t confined to food safety — it’s rapidly expanding to include sustainability, human rights, deforestation, and packaging accountability. Around the world, governments and retailers are pushing for stronger disclosure on issues that matter to consumers: where ingredients come from, how workers are treated, and what impact products have on the planet.
Europe is leading the charge. The EU Deforestation Regulation (EUDR), taking effect in December 2025, will require companies to prove that high-risk commodities like cocoa, coffee, palm oil, and soy are free from deforestation. At the same time, Extended Producer Responsibility (EPR) packaging laws are spreading globally, shifting the burden of recycling and waste management costs onto producers. For global food brands, this means FSMA 204 compliance is just one piece of a much larger puzzle.
Regulation is only half the story. Retailers are already setting bars higher than regulators. Many grocers and CPG giants now demand disclosure on labor practices, emissions, and packaging sustainability as conditions of doing business. If you can’t provide that visibility, you risk losing shelf space.
The upside? Early adopters become preferred suppliers. By using traceability data not only for FSMA 204 but also to prove sustainability claims, deforestation-free sourcing, or EPR compliance, companies earn trust with trading partners and consumers.
And once captured, this traceability data fuels entirely new value streams:
Analyze expiration dates, spoilage trends, and supply–demand mismatches to minimize product loss and improve efficiency.
Enable carbon accounting with a verifiable chain of custody for accurate emissions reporting across your supply chain.
Identify circular economy opportunities like ingredient reuse or packaging take-back programs to extend product life cycles.
Gain access to regions where sustainability and ethical sourcing are required for market entry.
Stand out with transparent, traceable data that earns preference from retailers and trust from consumers.
The advantages of that are extremely powerful. Retailers can pull all that rich supply chain detail connected to consumers, get feedback on the products that they purchase, and communicate additional information around sustainability, health, and nutrition. It's all converging around better communication tools bidirectional with consumers.— Andy Kennedy, Chief Traceability Officer, iFoodDS
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This is the part few companies have realized: much of the key supply chain data you collect for FSMA 204 compliance can be redeployed to address other factors such as sustainability, labor, deforestation, and packaging obligations. It’s one investment with exponential returns.
Consider this your inside track
Treat traceability as your strategic currency, and you’ll unlock new value streams, market access, and prime retail shelf space.
Secret #6
The Network is the future
Future-ready companies are moving past spreadsheets and one-off systems to embrace a digital ecosystem. That shift starts with data. AI-powered compliance platforms like TraceGains digitize and automate KDE capture from supplier documents, standardize data exchange, and bridge silos across the supply chain. This eliminates the manual burden and creates a single source of truth that can flow across trading partners.
In the end, what makes traceability work is collaboration—suppliers and buyers aligning on standards, sharing KDEs tied to CTEs, and ensuring that critical data like lot codes actually moves across the chain without being lost in translation.
That’s why the partnership between TraceGains and iFoodDS matters. TraceGains brings networked ingredient and supplier compliance data into the digital fold, while iFoodDS enables instant trace back and trace forward to the lot code.
Together, they form part of a larger digital transformation movement that helps companies move beyond compliance to resilience.
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“The basic unit of measure in traceability is that lot code. If you’re a supplier to retailers and food service and so forth, your customers are going to expect that you share that critical tracking event information with them when you ship them product. If you don’t comply and you can’t provide that information, over time, you will lose access to markets.“
— Andy Kennedy, Chief Traceability Officer, iFoodDS
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Consider this your inside track
Traceability isn’t a solo act—it’s a networked advantage.
The companies that thrive in this era won’t be the ones trying to build the tallest silo. They’ll be the ones plugged into the right networks, able to send and receive trusted data across trading partners, categories, and borders. That’s the real future of food safety and brand resilience.
Conclusion
Don’t keep the secret to yourself
The traceability era has arrived. FSMA 204 may be the catalyst, but the real story is bigger: traceability has become the foundation of consumer trust, retailer partnerships, and long-term growth.
Companies that digitize their supply chains now will be the ones shaping tomorrow’s food system. They’ll be able to turn data into trust, and trust into growth.
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“Traceability is a team sport. It requires a lot of engagement with your business and your supply chain partners. Don’t put it off. Wouldn’t it be better as a business owner to discover risks independently as a result of your traceability implementations rather than somebody else finding some sort of issue in your supply chain and having to manage the PR around that?”— Natalie Hunter, Managing Director, New Era Partners
This isn’t privileged information to keep quiet; it’s a roadmap that forward-thinking brands are already using to their advantage. The sooner you act, the stronger your resilience, your reputation, and your relationships will be.
Ready to unlock traceability for your business?
Partner with TraceGains + iFoodDS to future-proof your supply chain and lead in the traceability era.