FSMA 204 Compliance for Grocery Suppliers Starts With Your Data

In this article, learn about: 

• What the Food Safety Modernization Act (FSMA) 204 rule requires and how its date compares with retailer deadlines already in effect 

• What perishable advance shipping notice (ASN) specifications are 

• Why catch weight, lot codes, and temperature data lead to receiving problems and chargebacks 

Many grocery suppliers see cold chain as simply a trucking and warehouse issue. Trailers and temperature settings matter, but the data that travels with each shipment carries just as much risk. FSMA 204 compliance for grocery suppliers depends on accurate lot codes, dates, and weights, and many retailers already require that data in the ASN on every shipment. 

FSMA 204 is the Food Traceability Final Rule from the U.S. Food and Drug Administration (FDA). Its compliance date is now July 20, 2028, which removes the near-term federal deadline but not the retailer requirements suppliers face today.  

What Does FSMA 204 Require of Grocery Suppliers? 

FSMA 204 requires businesses that manufacture, process, pack, or hold foods on the Food Traceability List to keep specific records and give them to the FDA within 24 hours of a request. The list includes soft cheeses, tomatoes, and sprouts, and the rule also reaches certain foods that contain listed items as ingredients, according to the FDA final rule. 

The rule is built around two terms. A Critical Tracking Event (CTE) is a point where food is handled, and a Key Data Element (KDE) is a piece of information recorded there. The rule names seven CTEs: 

• Harvesting 

• Cooling before initial packing 

• Initial packing of a raw agricultural commodity 

• First land-based receiving of food from a fishing vessel 

• Shipping 

• Receiving 

• Transformation, such as manufacturing, repacking, or relabeling 

Shipping and receiving matter most for many grocery suppliers. A traceability lot code (TLC) ties the events together. It identifies a lot within the records of the company that assigned it, and every later record for that food includes it. 

Is the July 20, 2028 Extension a Reprieve? 

The extension gives suppliers more time with the federal rule and leaves retailer requirements where they were. The original compliance date was Jan. 20, 2026. The FDA proposed a 30-month extension. Congress then directed the agency not to enforce the rule before July 20, 2028, and the FDA says it intends to follow that directive. 

Some retailers moved well before either date. Kroger's Dec. 1, 2023 supplier letter asked suppliers to send an EDI 856 ASN for every shipment and to match their pallet and case labels to Kroger's receiving specifications. Suppliers also had to certify that the labels match the ASN, with the transition due by June 30, 2025. Kroger applies the requirement to all food products entering its facilities, not only foods on the list. Its director of food safety and regulatory compliance said the company chose that scope to avoid reconfiguring systems if the list changes, as Grocery Dive reported. 

The federal details may still change, since the FDA held a public meeting on June 15, 2026 about lot-level tracking and possible flexibilities. Retailer specifications apply to suppliers today either way. 

What Are the Perishable ASN Requirements Grocery Retailers Enforce? 

A perishable ASN identifies what is on each pallet and case, down to the lot and date, in a structure the retailer's receiving system can match against the physical label. Kroger publishes its specifications, so it works as a useful example. 

How Kroger Structures the ASN 

Kroger's ASN startup document describes a nested structure of shipment, order, tare, and pack levels. Each pallet carries a Serial Shipping Container Code (SSCC-18), and each pack level carries a case Global Trade Item Number (GTIN). Kroger expects complete, timely data and certifies suppliers by ship-from location after checking ASN accuracy. Its newer ASN frequently asked questions call for sending the ASN right after the truck door closes. 

Lot Numbers and Dates That Match the Label 

That FAQ lists several ASN fields that must match the physical label: 

Why Do Catch Weight and Lot Data Cause Errors? 

Catch weight items, such as fresh meat or cheese, are ordered in standard units like cases but billed by actual weight. GS1, the standards body behind barcodes, treats these as variable measure trade items, where the measure is an attribute of the item identifier and no new GTIN is needed. The actual weight then has to move from the label to the ASN and on to the invoice, because the purchase order, the receipt, and the invoice each hold part of the picture. Lot data adds a second variable, since the lot in the ASN has to match the lot printed on the case. 

The EDI fields that carry catch weight differ by retailer, so suppliers check them against each retailer's specification. Setups built around fixed-weight items often need changes before actual weight can travel through every document. 

Why Do ASN Errors Show Up at the Receiving Dock? 

Receiving teams check what arrives against what the ASN said would arrive. At Kroger, receiving runs against the purchase orders, pallet license plates, case GTINs, and quantities in the ASN, and exceptions go to the supplier along with scorecard performance. 

Kroger's EDI 824 application advice reports the results of its requirement checks, but the startup document says it does not flag data value errors, such as an invalid case GTIN or purchase order (PO) number. Kroger checks those after it loads the ASN. An ASN can pass the format checks and still fail at the dock. 

At the 2024 Food Safety Summit, Andy Kennedy of New Era Partners said receiving staff often do not trust the ASNs they get and inspect product by hand instead, as Food Safety Magazine reported. 

Cold Chain Chargebacks Grocery Suppliers Face 

Label and ASN errors carry direct fees at some retailers. C&S Wholesale Grocers, for example, may charge $50 or more for a missing or illegible label and $150 when the PO number on the label is wrong. 

Temperature adds a second exposure. Kroger required temperature loggers on each shipment of most commodities by Jan. 1, 2024, according to its supplier notice, and its current requirements call for continuous monitoring of inbound perishables, with out-of-range shipments subject to rejection on delivery. That temperature data moves through a separate cloud portal rather than the EDI network, so each perishable shipment produces two data streams that both have to be right. 

How Can You Meet Grocery EDI Traceability Requirements Now? 

Suppliers that get ahead of retailer requirements usually follow a sequence like this: 

1. First, they collect the current ASN and labeling specification from each retailer. 

1. Next, they map the pallet ID, lot, date, and weight fields on each label to the matching ASN fields. 

1. Then they test ASNs against the retailer's 997 and 824 responses before shipment volume grows. 

1. After launch, they review those responses and receiving exceptions weekly, since a label template error repeats on every carton. 

1. Throughout, they keep lot-level records that can meet a 24-hour FDA request. 

Gordon Food Service shows the same need from the distributor side. It worked with SPS Commerce to expand EDI use across its supplier network, cutting supplier onboarding from months to weeks while preparing for the KDE requirements of FSMA 204, according to its case study. 

Want To Check Your Grocery Data Before a Retailer Does? 

SPS Commerce Fulfillment helps suppliers send retailer-specific ASN data through EDI, and the Grocery & Food Services page covers FSMA 204 readiness and grocery traceability gaps. 

Not ready to talk with anyone? The Supply Chain Source has guides on GS1 labeling, ASN accuracy, and retailer compliance for suppliers. 

This article is for general information about food traceability and retailer requirements. It is not legal or regulatory advice, so double-check current details with the FDA and each retailer.