A Guide to Collecting Key Data Elements as a Grocery Retailer, Foodservice Operator, or Distributor

Note: This content has been updated to reflect the final version of FSMA Rule 204.

Now that FSMA Rule 204 has been finalized, it’s time to think about how you’ll comply with the new requirements. Start by familiarizing yourself with the Critical Tracking Events (CTEs) and Key Data Elements (KDEs) defined in the rule. According to the FDA, the receiving KDEs will be most often required for retailers and restaurants. However, retailers and foodservice operators may also be required to record shipping and transformation KDEs, based on the details of their operations. Read on to learn about these Critical Tracking Events and see how you can efficiently capture them.

What Is the Receiving Critical Tracking Event?

Receiving is defined by the FDA as “an event in a food’s supply chain in which a food is received by someone other than a consumer after being transported (e.g., by truck or ship) from another location.” In addition to tracking these KDEs across two different entities, the FDA also requires tracking of internal company shipments between two different locations.

In the final Rule, the agency clarified that “Receiving includes receipt of an intracompany shipment of food from one location at a particular street address of a firm to another location of the firm at a different street address.” In other words, retail stores and restaurant locations would function as receivers, even when accepting shipments from their own DCs. Receivers must capture the required Key Data Elements (KDEs) and link them to the traceability lot for the food.

What is the Shipping Critical Tracking Event?

According to the FDA, shipping is “an event in a food’s supply chain in which a food is arranged for transport (e.g., by truck or ship) from one location to another location. Shipping does not include the sale or shipment of a food directly to a consumer or the donation of surplus food. Shipping does include sending an intracompany shipment of food from one location at a particular street address of a firm to another location at a different street address of the firm.”

This new definition clarifies the question of whether the last-mile delivery from DC to store or restaurant would fall under Rule 204. The FDA has made it clear that even owned and operated DCs function as shippers and, as mentioned above, retail stores and restaurant locations function as receivers.

Shippers are not only required to capture their Key Data Elements and link them to the traceability lot but must also send their KDEs to the entity they are shipping to.

New Requirements for Central Kitchens

It’s also worth noting that there are new requirements for retailers and restaurants who prepare food on the Food Traceability List in a central kitchen and ship it to individual stores and restaurants. Under the final Rule, this activity would be considered transformation, and the retail or foodservice business would be required to capture these KDEs. However, if the food is prepared onsite at the store/restaurant and sold directly to the consumer, it would not fall under transformation. Consult this deck from the FDA to learn more about transformation KDEs.

The Link Between Shipping and Receiving KDEs

Almost every shipping KDE corresponds directly to a receiving KDE, which makes it critical to get the shipping KDEs from your suppliers. This ensures you’ll be able to record your own KDEs accurately.

How to Capture and Share Your KDEs Efficiently

Most of the foods on the Food Traceability List are highly perishable, so it is imperative that KDE collection does not disrupt speed and effectiveness when receiving orders. Many supply chain participants have expressed concern that FSMA Rule 204 requirements will place a large burden on their teams. iFoodDS has been actively participating in the discussion around traceability, FSMA 204, and how the industry can easily exchange valuable data. Here are our recommendations for efficiently collecting and sharing KDEs.

Get Shipping Information from Your Suppliers Electronically

It’s imperative that you receive your suppliers’ shipping information, including KDEs, electronically. While Rule 204 does not mandate electronic records, it does require you to provide relevant traceability information in an electronic spreadsheet within 24 hours of an FDA request. This is virtually impossible to do when your KDEs are stored on paper. Receiving shipper KDEs electronically will make it easier to record your own KDEs and will also help verify that what you received matches your order.

There are multiple ways to get supplier data in an electronic format:

Use ASNs

If you’re using Advance Ship Notices (ASNs) today, expand your ASN requirements to cover all the Key Data Elements you need to capture. Also require ASNs for all items on the Food Traceability List if you don’t do this already. This ensures you’re automatically receiving your KDEs before you even get a shipment. Once the product arrives, your team can verify the physical products match the ASN record.

Get the Data in a Flat File

You can also accept your suppliers’ data via a flat file, such as an Excel spreadsheet or CSV. They can export the file right from their ERP.

Require Your Suppliers to Label Cases and Pallets with Scannable Barcodes

Make sure your suppliers are putting a GS1-128 barcode on all cases and pallets. This allows you to verify that the physical products you receive match your electronic records.

Work with a Partner to Increase Your Visibility into the Data

Even with tools like ASNs and barcodes, data management can quickly become overwhelming. Consider working with a partner who can:

• Accept electronic records from suppliers in different ways. For example:
  • In a traceability software solution
  • An ASN accepted through Electronic Data Interchange (EDI)
  • An Application Programming Interface (API)
• Store the records securely in the cloud.
• Make KDEs visible to you, enabling you to track supplier compliance and traceback and traceforward across your supply chain.

This will give your suppliers options and make it easier for them to work with you.

Gain Full Visibility into Traceability Data with iFoodDS

iFoodDS understands the needs of enterprise organizations. We offer a Network Traceability Solution for grocery retailers, foodservice operators, and distributors. Reach out to our team to request a free consultation and see how we can help you prepare for FSMA Rule 204.

Our network solution enables you to:

• Track supplier compliance in an easy-to-use dashboard.
• Traceback and traceforward across your supply chain instantly.
• Give your suppliers options to capture and send their traceability data.
• Seamlessly onboard suppliers.

This material is for informational purposes only and not for the purpose of providing legal advice. You should contact your attorney to obtain advice with respect to any particular issue or problem.