- The FDA Food Traceability Rule compliance date is July 20, 2028. We will not imply that clock is now. + FDA has said it will not enforce the Food Traceability Rule before July 20, 2028, following a Congressional directive.
- A December 2023 first-party Kroger letter stated a June 30, 2025 supplier transition. We have not found a later first-party update. The letter's FDA date of January 20, 2026 is stale. The federal compliance date is July 20, 2028. This is not a claim that anyone is Kroger-ready. + A December 2023 first-party Kroger letter stated a June 30, 2025 supplier transition. We have not found a later first-party update. The compliance date under the rule remains January 20, 2026 (87 FR 70910); the extension is only proposed (90 FR 38084). FDA has said it will not enforce the Food Traceability Rule before July 20, 2028, following a Congressional directive. This is not a claim that anyone is Kroger-ready.
- July 20, 2028 · §1.1455 we do not claim to meet · No seals, competitor table, revenue-at-risk calculator + FDA enforcement not before July 20, 2028 · §1.1455 we do not claim to meet · No seals, competitor table, revenue-at-risk calculator
diff --git a/frontend/src/app/docs/fsma-204/page.tsx b/frontend/src/app/docs/fsma-204/page.tsx index 0a2d01ec4..70ad97197 100644 --- a/frontend/src/app/docs/fsma-204/page.tsx +++ b/frontend/src/app/docs/fsma-204/page.tsx @@ -38,7 +38,7 @@ const PROSE_LINK = const FACTS = [ { icon: Clock, label: '24-hour sortable-spreadsheet obligation' }, { icon: Shield, label: 'Aligned to 21 CFR § 1.1455(c)' }, - { icon: CheckCircle, label: 'Earliest enforcement date: July 20, 2028' }, + { icon: CheckCircle, label: 'FDA enforcement not before July 20, 2028' }, ]; const CTE_ROWS = [ @@ -124,7 +124,8 @@ export default function FSMA204GuidePage() {- FDA has proposed a 30-month extension and Congress directed FDA not to enforce before July 20, 2028. + The compliance date under the rule remains January 20, 2026 (87 FR 70910). The 30-month extension is only proposed (90 FR 38084). + FDA has said it will not enforce the Food Traceability Rule before July 20, 2028, following a Congressional directive. RegEngine tracks FDA timing changes so your team isn't relying on stale dates.
- The rule was finalized in 2022. The original compliance date was January 20, 2026. Congress directed FDA not to enforce the rule before July 20, 2028. The requirements themselves have not changed. + The rule was finalized in 2022. The compliance date under the rule remains January 20, 2026 (87 FR 70910). The 30-month extension is only proposed (90 FR 38084). FDA has said it will not enforce the Food Traceability Rule before July 20, 2028, following a Congressional directive. The requirements themselves have not changed.
{/* Enforcement callout */}The deadline moved. The rule didn't.
+The compliance date and enforcement timing are distinct.
- Congress directed FDA not to enforce before July 2028, but major retailers have published supplier traceability programs that pre-date the federal enforcement date. If you sell to a major retailer, check your supplier portal: your effective deadline may already have passed. + FDA has said it will not enforce the Food Traceability Rule before July 20, 2028, following a Congressional directive. Major retailers have published supplier traceability programs with their own timelines. If you sell to a major retailer, check your supplier portal: your supplier deadline may already have passed.
- Earliest FSMA 204 Enforcement Date: July 20, 2028 + FDA enforcement not before July 20, 2028
- Start with a free tool. See where you stand. Get compliant on your schedule, not the FDA's. + Start with a free tool. See where you stand. Build the records your operation and customers need.
The federal Food Traceability Rule compliance date is July 20, 2028.
+FDA has said it will not enforce the Food Traceability Rule before July 20, 2028, following a Congressional directive.
Estimates use simple multipliers applied to your reported hours, record volume, and revenue. We don't have verified customer ROI data yet, and the Founding rate reflects that. - Current public FDA posture points to July 20, 2028 as the earliest enforcement date; no public fine schedule exists, so the + FDA has said it will not enforce the Food Traceability Rule before July 20, 2028, following a Congressional directive. + No public fine schedule exists, so the risk-concentration tile is illustrative only. Actual results depend on your contracts, existing systems, staffing, and data hygiene.
diff --git a/frontend/src/app/tools/self-reported-checklist/components/SelfReportedChecklistClient.tsx b/frontend/src/app/tools/self-reported-checklist/components/SelfReportedChecklistClient.tsx index c526d8868..bce7c34af 100644 --- a/frontend/src/app/tools/self-reported-checklist/components/SelfReportedChecklistClient.tsx +++ b/frontend/src/app/tools/self-reported-checklist/components/SelfReportedChecklistClient.tsx @@ -10,7 +10,7 @@ export function SelfReportedChecklistClient() {- The federal Food Traceability Rule compliance date is July 20, 2028. + FDA has said it will not enforce the Food Traceability Rule before July 20, 2028, following a Congressional directive.
} diff --git a/frontend/src/app/trust/page.tsx b/frontend/src/app/trust/page.tsx index f201255d4..f76b4c166 100644 --- a/frontend/src/app/trust/page.tsx +++ b/frontend/src/app/trust/page.tsx @@ -189,7 +189,7 @@ const REGULATORY_BASIS = [ title: 'Current regulatory basis', items: [ 'FDA Final Rule: Requirements for Additional Traceability Records (21 CFR Part 1, Subpart S)', - 'Original compliance date: January 20, 2026; FDA has proposed a 30-month extension and Congress directed FDA not to enforce before July 20, 2028', + 'Compliance date under the rule: January 20, 2026 (87 FR 70910). The 30-month extension is only proposed (90 FR 38084). FDA has said it will not enforce the Food Traceability Rule before July 20, 2028, following a Congressional directive.', 'Food Traceability List (FTL): reviewed against FDA publications current as of April 1, 2026', 'FDA Q&A draft guidance: February 2026; FAQ updates reviewed June 2026', ], diff --git a/frontend/src/components/layout/marketing-footer.tsx b/frontend/src/components/layout/marketing-footer.tsx index c05926bf9..1063a21b2 100644 --- a/frontend/src/components/layout/marketing-footer.tsx +++ b/frontend/src/components/layout/marketing-footer.tsx @@ -95,7 +95,7 @@ export function MarketingFooter() { className="flex flex-wrap items-center gap-x-4 gap-y-3 border-t border-re-border-subtle py-4" > - FSMA 204 Enforcement: July 20, 2028 + FDA enforcement not before July 20, 2028 diff --git a/frontend/src/lib/constants.ts b/frontend/src/lib/constants.ts index 5d906d08f..2bf8bfced 100644 --- a/frontend/src/lib/constants.ts +++ b/frontend/src/lib/constants.ts @@ -52,11 +52,11 @@ export type ComplianceStatus = (typeof COMPLIANCE_STATUSES)[keyof typeof COMPLIA // ── FSMA 204 regulatory constants ───────────────────────────────────────────── /** - * FSMA 204 enforcement deadline. + * FSMA 204 date before which FDA has said it will not enforce. * - * Confirmed per FY 2025 Consolidated Appropriations Act, Division A, §775 - * (Pub. L. 118-158, signed March 2025). Congress directed FDA not to enforce - * the Food Traceability Rule before this date. Last verified: 2026-04-04. + * FDA has said it will not enforce the Food Traceability Rule before July 20, 2028, following a Congressional directive. + * The compliance date under the final rule remains January 20, 2026 (87 FR 70910). + * The extension in 90 FR 38084 is proposed only. */ export const FSMA_204_ENFORCEMENT_DATE = '2028-07-20'; export const FSMA_204_ENFORCEMENT_LABEL = 'July 20, 2028'; diff --git a/frontend/src/lib/fsma-enforcement.ts b/frontend/src/lib/fsma-enforcement.ts index 59f3ab472..b0ba6018f 100644 --- a/frontend/src/lib/fsma-enforcement.ts +++ b/frontend/src/lib/fsma-enforcement.ts @@ -1,10 +1,7 @@ -// Canonical FSMA 204 enforcement framing. FDA facts verified 2026-08-02: -// the Continuing Appropriations Act of 2026 (Nov 2025) directed FDA not to -// enforce the Food Traceability Rule before July 20, 2028, and FDA has stated -// it intends to comply. The Aug 2025 compliance-date-extension rule is still -// only a PROPOSED rule - never state the compliance date "was extended" as -// settled fact. The requirements themselves are unchanged. +// The compliance date under the final rule remains January 20, 2026 (87 FR 70910). +// The extension in 90 FR 38084 is proposed only. +// July 20, 2028 is the date before which FDA has said it will not enforce. export const FSMA_ENFORCEMENT_DATE = 'July 20, 2028'; export const FSMA_ENFORCEMENT_FRAMING = - 'FDA has been directed by Congress not to enforce the Food Traceability Rule before July 20, 2028, and has stated it intends to comply. The requirements are unchanged; only enforcement moved.'; + 'FDA has said it will not enforce the Food Traceability Rule before July 20, 2028, following a Congressional directive.'; diff --git a/frontend/src/lib/fsma-tools-data.ts b/frontend/src/lib/fsma-tools-data.ts index 0952b8e30..851c2e7ef 100644 --- a/frontend/src/lib/fsma-tools-data.ts +++ b/frontend/src/lib/fsma-tools-data.ts @@ -1,16 +1,16 @@ /** * FSMA 204 Key Dates - * Based on FDA Final Rule and Congressional enforcement directives - * Original compliance date was January 20, 2026. Congress directed - * FDA not to enforce before July 20, 2028. + * The compliance date under the final rule remains January 20, 2026 (87 FR 70910). + * The extension in 90 FR 38084 is proposed only. + * FDA has said it will not enforce the Food Traceability Rule before July 20, 2028, following a Congressional directive. */ export const FSMA_204_ORIGINAL_DATE = 'January 20, 2026'; -export const FSMA_204_COMPLIANCE_DATE = 'July 20, 2028'; +export const FSMA_204_COMPLIANCE_DATE = 'January 20, 2026'; export const FSMA_204_ENFORCEMENT_FLOOR = 'July 20, 2028'; export const FSMA_204_DEADLINE_ISO = '2028-07-20'; export const FSMA_204_CITATION = '21 CFR Part 1, Subpart S'; -/** Days remaining until the compliance deadline */ +/** Days remaining until the date before which FDA has said it will not enforce. */ export function daysUntilFSMA204(): number { const now = new Date(); const deadline = new Date(FSMA_204_DEADLINE_ISO);