Ohio State helping retailers prepare for new FDA rule reshaping food safety tracking

COLUMBUS, Ohio - If a foodborne illness outbreak hits, every minute counts.

The faster a contaminated food can be traced to its source, the faster it can be pulled from shelves and plates. But for many retail food businesses, that's easier said than done. A sweeping new federal traceability rule is about to raise the stakes, and The Ohio State University College of Food, Agricultural, and Environmental Sciences (CFAES) is here to help.

Aimed at strengthening the nation's food safety net, the U.S. Food and Drug Administration's (FDA) Food Traceability Rule requires that businesses handling certain high-risk foods keep more detailed records so regulators can quickly track and remove products in the event of an outbreak.

While the rule's original compliance deadline of January 2026 has been extended by 30 months, the urgency behind it hasn't changed.

That's why CFAES is working to prepare retailers, especially small and independent operators, before the new requirements take effect in 2028.

"The Food Traceability Rule is going to be a major shift for retail food establishments, many of whom have never had to deal with this level of oversight," said Nicole Arnold, assistant professor and food safety field specialist with Ohio State University Extension, CFAES' outreach arm.

"Traceability isn't just about compliance. It's about protecting consumers, preserving trust and minimizing economic fallout from recalls."

To help businesses prepare, CFAES has partnered on a national effort to make traceability training more accessible. A free, virtual course developed by NC State University's Safe Plates team, along with Ohio State, North Carolina Agricultural and Technical State University, and High Point University, provides retailers step-by-step guidance on how to comply.

Course details and registration are available at go.ncsu.edu/traceabilitycourse .

The course is tailored to small operators and includes two parts: about 45 minutes of self-paced pre-course work, followed by a live, virtual or in-person session where participants begin drafting their own traceability plans. Upon completion, attendees earn a certificate they can share with inspectors or corporate partners.

Participants learn which foods are covered, what data they need to collect, how to communicate with suppliers, and what systems they can use to keep records organized, whether electronic or paper-based.

"For small operations, the idea of an 'electronic sortable spreadsheet' can be intimidating," Arnold said. "Cost is often a barrier. We want to help them find solutions that work for their business size and resources, not impose a one-size-fits-all approach."

What's changing and why it matters

The Food Traceability Rule, part of the FDA's Food Safety Modernization Act (FSMA) 204 , targets foods most commonly linked to outbreaks, including leafy greens, soft cheeses, certain seafood and ready-to-eat deli salads. Businesses that manufacture, process, pack or hold these foods must now track "Key Data Elements" (KDEs) tied to "Critical Tracking Events" (CTEs), such as receiving, transforming or shipping the product.

If the FDA suspects contamination, affected businesses must be able to provide that information quickly.

"The rule says entities must provide data to FDA within 24 hours of request, or within another agreed-upon timeframe," Arnold said. "That's not a lot of time. You have to be prepared before something goes wrong."

Without preparation, the risks multiply. Delays in traceability can prolong outbreaks, increase the number of people who get sick and lead to broader product recalls. For small businesses and retailers, the costs of noncompliance, or a reputational hit, can be devastating.

Even with training available, putting the new traceability requirements into practice can be daunting.

Initial feedback from Ohio retailers points to steep learning curves, especially with unfamiliar terms like KDEs, CTEs and "Traceability Lot Codes" (TLCs). Some worry about the technology and time required. Others are unsure how to work with suppliers to align systems.

That's where OSU Extension's role is critical.

"Our job is to take this complex regulation and make it manageable," Arnold said. "We're here to walk people through it and help them build the confidence and capability to succeed."

Beyond business compliance, Arnold emphasizes the broader goal of protecting public health. As global supply chains become more complex, the ability to trace contaminated food quickly is vital.

"Every day we delay removing contaminated food from the market, more people could get sick," she said. "That's why traceability is so important, and why this training matters."

Ohio State's involvement is supported by the U.S. Department of Agriculture's National Institute of Food and Agriculture through the Food Safety Outreach Program. With more training dates planned for 2026, Arnold said now is the time to act.

"The compliance deadline may seem far away, but it's coming fast," she said. "The sooner retailers start learning and preparing, the better positioned they'll be to protect their customers and their business."