Every major grocer's traceability deadline has already passed. FDA's is 2028.

Here is the state of play, in one table.

Every date in that table except the last one is either in the past or being enforced today.

If you have been treating July 2028 as your deadline, you have been planning against the single least urgent date that applies to you.

Why the extension didn't help

When Congress made the 30-month extension binding and FDA's compliance date moved from January 2026 to July 20, 2028, a lot of small producers exhaled. Trade coverage framed it as breathing room.

It was not, for a reason that is obvious once stated: retailer deadlines were never pegged to FDA's calendar. They were set against each retailer's own recall exposure and systems roadmap. Kroger published its accelerated timeline in late 2023, which made it the first major grocer to do so, and Walmart and Wegmans followed within months. None of those dates moved when the federal one did. They had already passed by the time the extension mattered.

The federal rule sets a floor. Your buyer sets your actual deadline, and your buyer is the party that can stop your purchase orders this quarter. FDA cannot do that until 2028.

What each one actually asks for

The specifics are in the individual teardowns, but here is the shape of each program.

Kroger wants an EDI 856 ASN on every shipment, logistic units aligned to its Track and Trace receiving specs, and dock barcode labels certified to match the ASN. Its scope is all food products, not just the Food Traceability List, in its own words.

Walmart wants an ASN carrying KDEs on every food shipment, SSCC-18 pallet barcodes linked to that ASN, and GS1-128 case barcodes. Also all food products, with baby food, pet food, beverages, meat, and poultry named explicitly. Walmart is the one that publishes consequences: freight rejection, monetary fines, and relationship review for repeat violations.

Wegmans wants FTL self-identification at new-item setup, an EDI 856 ASN, an SSCC pallet label matching the ASN, and a GS1-128 case label.

Costco does not run a single dated traceability program. It runs a supplier program whose traceback bar is two to four hours, well inside FDA's 24, plus GFSI certification, mock recalls, mass balance reconciliation, and GS1-128 case labels tied to the EDI 856 ASN with per-carton chargebacks for labeling failures.

Whole Foods stacks four separate audits rather than issuing a traceability deadline. Traceability shows up inside them.

Aldi, H-E-B, Meijer, and Publix have been reported as having deadlines earlier than FDA's, in reporting drawn from ReposiTrak's supplier network data. None has published a specific public date. That does not mean the requirement is soft. It means it will reach you through new-item setup or a portal invitation rather than a press release, which is a worse way to find out.

The convergent spec

Read those five programs side by side and the reassuring thing is how much they overlap. Three requirements do almost all the work:

1. An advance ship notice carrying lot-level data. Every program routes traceability through the EDI 856 ASN rather than a separate traceability document. If you have no EDI capability today, this is your long-lead item. It is a procurement decision measured in weeks, not a form.

2. GS1 identifiers on the physical units. GTINs, SSCC pallet codes, GS1-128 case labels. FSMA 204 itself requires none of this, and that remains true. But Costco, Kroger, Walmart, and Wegmans all effectively require it, which makes a GS1 Company Prefix the cost of national grocery shelf space regardless of what the federal rule says.

3. A lot code that reconciles between the label and the message. This is the one that fails. Every program checks that the physical thing arriving at the dock describes the same lot as the electronic message that preceded it. When they disagree, you get a rejection or a chargeback.

Point three is also the one FDA's own research says the industry is worst at. In FDA's spring 2026 traceability readiness tabletop exercises, only 40 percent of participating firms captured a properly assigned Traceability Lot Code across every Critical Tracking Event they performed. The lot code exists on the label. It never made it into the record, so every downstream use of it is a human retyping it, and that is exactly where label and message drift apart.

Build once, express many

The failure mode I want to warn against is treating each retailer as a separate project. Producers who do that burn out around retailer number three, because each program has its own portal, its own field names, and its own onboarding contact.

The underlying data is nearly identical. For any finished lot you need to know: the lot code, when it was made, where the code was generated, which supplier lots fed it, and which customers received how much on what date. That is one dataset. The KDE checklist by event type lays out exactly which fields belong on which record.

Get that right once and each new retailer becomes a mapping exercise rather than a rebuild.

A 30-minute audit you can run today

Before you touch any retailer portal:

1. Ask each of your grocery buyers what their traceability requirement and deadline are. Especially if they are Aldi, H-E-B, Meijer, or Publix, where nothing is public. One email per buyer.
2. Pick one lot you shipped last month. Write down its lot code, the supplier lots that fed it, and every customer who received it, using only records you already have.
3. Check whether the lot code on your production record matches the one on the case label. If a human retyped it anywhere in between, that is your reconciliation risk.
4. Find out if you can send an EDI 856 ASN today. If the answer is no or "I would have to ask," start that conversation this week.

Step 1 is free and it is the one nobody does. Most producers discover a retailer requirement when it blocks a shipment.

Where FSMA204Hub fits

Every program above reduces to the same question asked in a different dialect: for this lot, what went in and where did it go?

That is the bet behind FSMA204Hub. One row per finished lot, inputs and customers hanging off the same code, so answering a buyer means filtering and exporting rather than reconciling two systems under a deadline. The compliance score flags which lots would fail that question before a receiving dock does it for you.

If any of the dates in that table apply to you, start a free 14-day trial. No credit card. We answer questions within a working day.

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Got a retailer deadline that is not in the table above? Email [email protected] with the retailer and what they asked for. I keep this page updated and will credit you.

Further reading

• Walmart: Food traceability supplier requirements
• Grocery Dive: How grocers are taking charge of food traceability requirements
• FDA: Food Traceability Final Rule

Related on this site

• Walmart supplier traceability requirements
• Kroger supplier traceability requirements
• Wegmans supplier traceability requirements
• Costco supplier traceability requirements
• How to pass a Whole Foods supplier audit
• ReposiTrak supplier onboarding: a 7-day playbook

Written by Anas Marwan, Co-founder of Darza Technologies. Last reviewed 2026-08-11.