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Food Labels, Traceability, and the FSMA

The Food Safety Modernization Act  (FSMA) was signed into law in January 2011, creating some of the largest changes to food safety in over 70 years. The new regulations in the FSMA affect the entire supply chain from farm-to-fork. The FSMA requires changes for most food retailers and gives consumers important tools to determine safe food.

The FSMA has been gradually implemented over time, and 2017 marks the first year of full compliance. Food manufacturers, distribution centers, food importers and food transporters are all impacted by the FSMA and its goal of preventing contamination of all food products. Both imported and domestic foods are held to the same standard, and compliance documentation must be in place and accessible. The FDA has the power to request records, inspect facilities, and even shut them down if compliance is not satisfactory.

Two significant portions of the FSMA include traceability and allergen labeling.


The FSMA expands the FDA’s access to records for review. Food suppliers need to have both backward and forward traceability (be able to identify where all the ingredients came from and where they went), which is usually achieved using barcoding. This is why we are seeing such an increase in the use of GS1 128 barcodes that include the lot number for traceability. With traceability measures in place, consumers can be notified of recalls due to contamination or inaccurate or incomplete allergen information on the label.

Allergen labeling

The FDA has designated eight major foods or food groups that account for 90% of food allergies. These foods are:

  • milk
  • eggs
  • fish
  • crustacean shellfish
  • tree nuts
  • peanuts
  • wheat
  • soybeans

Since food allergies are so serious and an allergic consumer must avoid any allergen found in certain foods, clear and accurate labeling is a must at the retail level. It is estimated that about 200,000 emergency room visits annually are caused by food allergies and incorrect allergy labeling was the single biggest cause of food recalls in 2015.


In addition food labels, food packagers must also comply with FSMA requirements. Packaging that touches food is treated as food. So any type of plastic or foil package, can, or box that comes into contact with the food product must be labeled with lot information. That lot information and other data is then captured and tracked along the supply chain as it is used with the food product and can be tracked back to the packaging vendor if necessary.

barcodes for FSMA traceability

GS1 128 Barcode can include both product ID (GTIN) and lot nunber for traceability

The packaging in which finished food products are shipped, or outer packaging, must be tracked as well. Lot numbers or manufacturing dates are required. For example, when a container full of boxed pasta is shipped, the receiver must collect the lot number, manufacturing date or expiration date of the lot, and the size of the pasta boxes. This information is provided on the outside of the container and allows for tracking the food (and packaging) through any further production or shipping, and then that information is provided to the consumer.

Are you involved in food labeling or packaging and need to comply with the new food labeling requirements?  For help with your labels or packaging, or any other aspect of your labeling, marking, or coding, contact us. Call 888-438-3242 Option#3, or contact David Holliday directly at dholliday@idtechnology.com. We’ll get you in touch with one of our ID Technology specialists in your area.


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