On the 20th of March 2025 the FDA announced its intention to move enforcement of the Food Traceability Rule (FSMA 204) 30 months down the road—from 20 January 2026 to 20 July 2028. The extra time is a welcome breather, not a break. To walk into 2028 ready, the supply chain needs to keep building a shared language for data. That’s where GS1 comes in. U.S. Food and Drug Administration
The safety mandate behind the standards
FSMA, signed in 2011, shifted U.S. food law from reaction to prevention. Section 204, finalized in November 2022, zeroes in on traceability: companies that touch foods on the Food Traceability List must record Key Data Elements (KDEs) at every Critical Tracking Event (CTE) such as growing, receiving or shipping. Speedy traceback saves lives. The CDC estimates that foodborne illness strikes 48 million Americans a year, hospitalizes 128,000 and claims 3,000 lives. CDC
How GS1 closes the communication gap
GS1 is a neutral, non-profit standards body whose identifiers make data unambiguous everywhere in the world.
When produce, packaging, and paperwork trade hands a dozen times on their way from farm to store, every company in the chain ends up with its own item codes and location nicknames. That jumble makes it hard to trace a shipment—or to prove compliance—without time-consuming translations. GS1 standards fix the problem by giving every product, every place, and every event a single, globally understood identifier. Fold those IDs into purchase orders, shipping notices, and scan data, and the fragments knit together into one clear story that any partner or regulator can read. Here are the three building blocks that make it work:
- GTIN – the product ID. The Global Trade Item Number pins a single, specific item (size, variety, pack) so every partner is talking about the same thing.
- GLN – the place ID. The Global Location Number singles out farms, packhouses, warehouses or legal entities, linking product movement to a precise “where.”
- EPCIS – the event language. Electronic Product Code Information Services captures and shares the “what, when, where, why” of each event, turning scattered transactions into one story the whole chain can read.
Barcodes: the physical link
Digital IDs only work if they travel with the goods. GS1-128 and GS1 DataMatrix barcodes encode a GTIN, lot code, dates and other KDEs directly on cases, pallets—or even each item. One scan at receiving or shipping pulls the right data into the traceability record, slashing manual entry and mis-keys. Because every barcode follows the same rules, any partner’s scanner can read it, no matter whose software sits behind it.
Getting started with GS1
– License a GS1 Company Prefix and assign or verify GTINs for every sellable unit.
– Create GLNs for farms, facilities, docks—any spot that could appear in a traceability record.
– Map which events you’ll capture in EPCIS and how that data will flow to partners.
– Print GS1-128 or DataMatrix barcodes that carry GTIN, lot and date so KDEs are captured automatically.
– Train internal teams and suppliers on the exact data points, formats and hand-off moments.
A first, simple task: audit where GTINs or GLNs already live in your systems, note the gaps and tackle those first.
Take the next step
Download GS1 US’s “FSMA 204 Quick-Start Guide” and share it with your project team. Standardizing your internal systems will help when passing and receiving data to ensure everyone is speaking the same language!
Throughout the coming weeks I will tackle the GS1 standards starting with how and why the GTIN will help with traceability and data integrity.
Having trouble getting your suppliers to send the regulatory documents you need? Get in touch with us here.
Learn More about GS1 and their FSMA standards: Food Safety Modernization Act (FSMA) | GS1 US – a hub of FSMA 204 resources