What the FDA's June 15 lot-level traceability meeting means for small producers

For the first time since the Food Traceability Rule became final, the FDA is publicly asking a question that every small producer has been muttering for two years: is lot-level tracking actually workable for a business your size?

On June 15, the agency is holding a virtual public meeting to find out. It published a discussion paper to frame it. And it left a comment docket open until July 15.

If you make artisan cheese, nut butter, sauces, or cut produce and you have ever stared at a tray of finished product wondering how on earth you are supposed to assign and carry a unique lot code through every step, this is the meeting where the people writing the rule are asking you to tell them what is hard.

There is one catch, and it is a date. If you want to speak during the public comment period, you have to register by Friday, June 5. That is the reason this post is going out today and not next week.

What the meeting actually is

The meeting is called Challenges and Solutions in Lot-Level Food Traceability. Here are the facts that matter:

Registration is being handled through the Partnership for Food Traceability. If you already registered through them, you do not need to do it again.

Why this meeting exists at all

This did not come out of nowhere. In November 2025, Congress passed the Continuing Appropriations Act, and it did two things to FSMA 204 in the same breath:

1. It directed the FDA not to enforce the rule before July 20, 2028. That is the deadline extension you have probably already heard about.
2. It directed the FDA to engage with regulated businesses on a regular basis to find and, where appropriate, implement "additional flexibilities" for the lot-level tracking requirement.

The June 15 meeting is part of that second mandate. The FDA is not reopening the whole rule. It is asking a narrower question: where is lot-level tracking too costly, too confusing, or too impractical, and what could the agency change to make it easier without losing the ability to trace a contaminated lot in a hurry?

That narrow question happens to land right on top of the exact thing small producers struggle with most.

What FDA is actually asking about

The discussion paper centers on the traceability lot code (TLC), and specifically on the moments where assigning and carrying one gets messy:

• Transformation. When you take ingredients on the Food Traceability List and turn them into a new FTL food, you assign a new TLC. For a creamery turning milk into chevre, or a producer turning cucumbers into a fresh pack, the rule treats that as a transformation event with its own lot code.
• Commingling and repacking. When you blend lots together, or repack from a bulk container into retail units, the question of which lot code travels forward gets genuinely hard. This is where a lot of small operations quietly break the chain.
• The everyday burden of it all. Carrying a unique code through receiving, production, and shipping, and being able to walk it backward to ingredients and forward to customers, is a real operational tax when you are a team of three running on spreadsheets.

If you want the plain-language version of how these three concepts fit together before you read anything the FDA publishes, that is exactly what our TLC vs. KDE vs. CTE primer is for. The meeting is, in effect, the FDA admitting that this trio is hard and asking the industry where to add slack.

What this changes, and what it absolutely does not

Here is the part where you have to read carefully, because it is easy to take the wrong lesson from "the FDA is considering flexibilities."

What it could change, eventually: the FDA might, after this meeting and the comment period, propose ways to lighten the lot-level tracking burden for certain operations or certain events. That is a real possibility and it is worth your voice. Nothing changes on June 15 itself. Any actual flexibility would come later, through a separate process, on the FDA's timeline.

What it does not change, starting tomorrow: your buyers are not waiting for the FDA. Costco, Whole Foods, Wegmans, and Erewhon are pushing lot-level traceability onto suppliers through ReposiTrak and supplier questionnaires right now, in 2026, regardless of what the FDA decides about flexibilities in 2027 or 2028. A retailer audit does not care that the FDA held a meeting. The questionnaire your buyer sent you is still due on the date they set.

So the honest framing is this. The June 15 meeting is where you advocate for an easier rule. It is not a reason to slow down on the traceability your retailers are already demanding. Those two things live on completely different clocks. Treat the meeting as your chance to be heard, not as permission to wait.

How to make your voice count before June 5

If you do one thing this week, make it this: decide whether you want to speak or write.

If you want to speak on June 15, register through the Partnership for Food Traceability by Friday, June 5. You do not need a polished statement. The most useful comment you can give is concrete and specific: "Here is the exact step in my process where assigning a lot code costs me X hours a week, and here is what would make it workable." Regulators hear from consultants and large processors constantly. They rarely hear from a four-person creamery describing the real cost of a single CTE.

If you would rather write, you have until July 15 to submit a comment to docket FDA-2014-N-0053 on regulations.gov. Written comments carry the same official weight and you can take your time with them.

A few things worth raising, if they are true for you:

• Where transformation or commingling forces a lot-code decision that your current system cannot cleanly make.
• Whether the recordkeeping exemption thresholds (the rule does not apply below roughly $250,000 in average annual food sales, and the electronic-spreadsheet requirement drops below roughly $1,000,000) match the reality of who actually has the staff to comply.
• The gap between what a retailer portal demands today and what the rule will require in 2028, and how a small producer is supposed to bridge it.

What to do while you wait

Advocacy is the long game. The short game is the buyer who is going to ask you for a clean lot trace this quarter. The two are not in tension. The producer who shows up to the June 15 meeting with a working traceability system is also the producer whose comment carries the most weight, because they are describing real friction, not hypothetical friction.

If you are not sure where your own system stands, that is the place to start. Our FSMA 204 Compliance Score quiz takes about five minutes and tells you which parts of lot-level tracking would bite you in a retailer audit today. And if the specific question is whether your lot codes are actually valid, the TLC Validator will check the format in a few seconds.

Then, when June 15 comes, you will be in the room as someone who has done the work and can say exactly where the rule made it harder than it needed to be. That is the comment the FDA is asking for.

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We will update this post after the June 15 meeting with what the FDA heard and what it signaled about next steps. Bookmark it if you want the follow-up.