Traceability Newsletter

8 June 2022

Traceability Newsletter

Food Safety & Traceability – Learnings From a Recent US Trial

Fresh Produce Traceability is a challenge internationally. Regulatory changes in the America will impact on how is managed there. This  is of interest in New Zealand, both as an exporter of fresh produce, and because certain “high risk” fresh produce items have been singled out in the regulations.

Companies producing or handling foods on the US Food and Drug Administration (FDA) Food Traceability List (FTL) will be required to generate and maintain more detailed records, under a proposed rule aiming to strengthen food traceability of high-risk products. More than 20 categories of fresh and processed foods are affected, including several types of fruits & vegetables such as beansprouts, leafy greens, herbs, melons and ready to eat fruits and vegetables.

These foods have been singled out for more detailed tracking information because they are the most common sources of foodborne illness outbreaks in the U.S.

Globally, there is a trend towards differentiating levels of food safety risks across fresh produce. In New Zealand, the Risk Ranking Project completed in 2021 highlighted similar fresh produce lines as requiring attention.

The new mandatory recordkeeping procedures go beyond the traditional "one-up, one-down" traceback, and incorporate more robust data. The FDA’s new rule would specifically require persons who "manufacture, process, pack, or hold" foods on the list to record certain Key Data Elements(KDEs), which are associated with different Critical Tracking Events (CTEs) in the supply chain.

Each product needs its own unique identifier, and traceability lot code, to be captured at every step in the supply chain process. Supply chain partners will be required to provide the data to FDA within 24 hours in the event of an outbreak. This will allow investigators to determine the next steps, such as withdrawing or recalling affected products, quickly & accurately.

Sharing this additional data could dramatically change the entire food system, by enabling full end-to-end traceability. Wider adoption across other food categories, beyond the initial list, could extend the benefits even further, improving the safety of the U.S. food supply.


Standards Support Collaboration

Standardised data systems are key to sharing supply chain details quickly & efficiently. Throughout many industries, GS1 Standards are already being implemented, enabling a multitude of benefits beyond traceability, such as improving supply chain efficiencies and inventory management.

These standards include:

  • Product identification with Global Trade Item Numbers (GTINs), which uniquely identify an item, making it visible in the supply chain. The GTIN can be embedded in UPC barcodes for checkout use, or in GS1-128 barcodes identifying cases & pallets. GS1-128 barcodes can also encode additional data, such as expiration dates, batch/lot/serial numbers, quantities, weights, and other product information.
  • Location identification with Global Location Numbers (GLNs), which identify locations and companies, such as farms or fields, packing houses, manufacturing plants, wholesalers, and more.

Some mechanisms for data collaboration across the supply chain are outlined.

  • Master product data-sharing via the Global Data Synchronization Network™ (GDSN), an automated global data exchange network, allowing trading partners to share trusted product data. This helps in meeting increasing consumer demands for accurate, complete, and consistent product information.
  • Transactional data sharing, via Electronic Product Code Information Services (EPCIS), which processes transaction events (e.g., shipping/receiving information), to maintain a complete product history along the entire supply chain.

 Data sharing mechanisms such as these are likely to become increasingly important in supporting effective traceability.



The complexity of modern supply chains means that they need to become more seamlessly digitised, to protect consumers from potentially harmful foods. Higher levels of systems interoperability are needed.

When trading partners’ systems can easily & quickly transmit consistent information throughout the supply chain, foods are more traceable, especially in the event of a crisis.

The following are three takeaways from a recent GS1 USA study highlighting the importance of interoperability. 


  1. A standards-based framework is essential.

GS1 Standards identify products, entities, locations, Critical Tracking Events, and Key Data Elements, to support the interoperability of systems in one recent study. GS1 Standards were vital to these two requirements for interoperability: This includes Globally unique identification, such as the use of Global Trade Item Numbers (GTINs) for products, and Global Location Numbers (GLNs) for identifying entities & locations.

Standardised data models for sharing data across platforms, helps capture and share event-based data and effectively connect the traceability systems involved. The GS1 EPCIS system is one such potential system.

GS1 US also worked with the seafood industry, testing the flow of Traceability data using seafood specific traceability standards. While these standards helped give the participant systems the ability to “speak” to each other, the industry collaboration using GDST as equally critical to define what data was shared within the network, and how.


  1. Diverse technologies must be Interoperable

To achieve a truly visible and traceable supply chain, the integration of internal and external business processes must occur.

The internal processes a company uses to track a product within its operation needs to be integrated into a larger system of external data exchange & business processes that transmit traceability data along the supply chain. The focus needs to be on the network of trading partners sharing data and the data trustworthiness.


  1. Interoperability is core to effective traceability systems.

Interoperability allows enhanced data exchanges, with the necessary speed & efficiency to keep up with consumer demands.

Harmonising food traceability systems is critical to helping prevent food safety issues before they arise.

One weak link in a food supply chain, unable to maintain & exchange the necessary data in a way that partners can understand, update, and send to the next entity in the supply chain, prevents full traceability.


Further Resources

United Fresh Traceability guidelines and resources

FSMA Proposed Rule for Food Traceability

FDA Food Traceability List