Food Defense

Kroger sets the bar on Food Traceability

March 18, 2024 | 2 Min Read

In December 2023, one of the largest food retailers in the United States issued a letter to all their suppliers announcing their plan to comply with the FDA’s Food Traceability Rule. The letter read in part:

“The Kroger Co (“Kroger”) is working diligently to implement FDA’s Food Safety Modernization Act, Section 204(d), also known as FSMA 204. FSMA 204 establishes traceability recordkeeping requirements, beyond those in existing regulations, for persons who manufacture, process, pack, or hold foods. The requirements in the Final Ruling allow for faster identification and rapid removal of potentially contaminated food from the market, resulting in fewer foodborne illnesses and/or death. Ensuring the safety of food supply for our customers is a shared responsibility across our supply chain network.”

The letter went on to state that Kroger intends to collect and record traceability information for all food products entering Kroger facilities. This is a bold statement in that the FDA does not require traceability information on all foods; the requirement only covers food products such as non-pasteurized cheeses, nut butters, many categories of fresh produce, fresh seafood, and ready-to-eat deli salads.

Click here for the full letter Kroger sent to their suppliers.

Establishing a traceability system is a regulatory requirement in the United States for companies associated with food production and handling. This requirement will go into full effect January 2026, with civil and criminal penalties for non-compliance.

Ensuring that your traceability actions are proactive, not reactive, is critical to securing the movement of food materials in the supply chain. To effectively implement both of these requirements, you must have a dynamic system in place to ensure that the bulk ingredients unloaded at your facility were not adulterated in transit. The FDA is clear that it is the food production facility (question FD.4), not the carrier, that must take mitigation steps necessary to protect the cargo during transit.

Surelock Seals provides that system. We are your Out of The Box solution for food traceability and security, offering both handheld and stationary RFID reader options to fit your budget. Our RFID seals are attached to the trailer hatches after the bulk ingredient is loaded, and if tampered with in transit, they will be permanently destroyed, informing you of possible adulteration.

If you have questions regarding food traceability or the FSMA, check out this previous article on those topics.

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