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Your Guide to FSMA 204 Compliance

The latest updates to FSMA 204 and what ArrowStream is doing to ensure you are compliant.

Countdown to January 20, 2026 Compliance Deadline

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Frequently Asked Questions

Your Guide to FSMA 204 Compliance

The latest updates to FSMA 204 and what ArrowStream is doing to ensure you are compliant.

Countdown to January 20, 2026 Compliance Deadline

Days
Hours
Minutes
Seconds
Frequently Asked Questions

Staying compliant with FSMA 204 doesn't have to be complicated—especially when ArrowStream has you covered.

As an ArrowStream customer working with a compliant distributor, you’ll have tools and support to ensure compliance with the minimum requirements while staying informed on future enhancements.

General FSMA 204 FAQs

The Food Safety Modernization Act (FSMA) is a U.S. law designed to improve food safety. It grants the FDA authority to regulate how food is grown, harvested, and processed.

The final rule establishes additional additional traceability recordkeeping requirements for those that manufacture, process, pack or hold certain foods, including fresh leafy greens, nut butters, fresh-cut fruits and vegetables and ready-to-eat deli salads. In collaboration with industry, the FDA will be able to more rapidly and effectively identify the origin and route of travel of certain contaminated foods to prevent or mitigate foodborne illness outbreaks, address credible threats of serious adverse health consequences or death, and minimize overly broad advisories or recalls that implicate unaffected food products.
Because the Food Traceability Final Rule requires entities to share information with other entities in their supply chain, the most effective and efficient way to implement the rule is to have all persons subject to the requirements come into compliance by the same date. The compliance date for all persons subject to the recordkeeping requirements is Tuesday, January 20, 2026.
  • Many fresh fruits and vegetables:
    • Fresh cucumbers, herbs, leafy greens, melons, peppers, sprouts, tomatoes, tropical tree fruits, all fresh-cut fruits, and all fresh-cut vegetables
  • A variety of soft cheeses:
    • Fresh soft, soft un-ripened, soft ripened, and semi-soft cheeses made from pasteurized milk
    • Cheeses made from unpasteurized milk, other than hard cheeses
  • Shell eggs
  • Nut butters
  • Some categories of seafood:
    • Fresh and frozen finfish, refrigerated and frozen smoked finfish, fresh and frozen crustaceans, and fresh and frozen molluscan shellfish and bivalves
  • Refrigerated RTE (ready-to-eat) deli salads
  • Harvesting
  • Cooling
  • Initial Packing (applies to Raw Agricultural Commodities not obtained from a fishing vessel)
  • First Land-Based Receiver (applies only to seafood)
  • Shipping
  • Receiving – this is where ArrowStream will primarily assist
  • Transformation

Every step in the process requires slightly different KDEs, but for the receiving at the restaurant location, it’s required to collect the following:

Traceability lot code for the food

  • Quantity and unit of measure of the food
  • Product description for the food
  • Location description for the immediate previous source (other than a transporter) for the food
  • Location description for where the food was received
  • Date you received the food Location description for the traceability lot code source or the traceability lot code source reference
  • Reference document type and reference document number
Create and maintain a traceability plan Maintain records as original paper records, electronic records, or true copies (must be legible and stored to prevent deterioration or loss).​
  • Provide traceability records (and any information necessary to understand these records) to the FDA no later than 24 hours after a request is made (or within a reasonable time to which the FDA has agreed).​
  • Provide an electronic sortable spreadsheet containing relevant traceability information to the FDA within 24 hours of a request (or within some reasonable time to which the FDA has agreed) when necessary to assist during an outbreak, recall, or other public health threat.
For more information and the latest updates, you can consult the FDA website.

ArrowStream and FSMA 204 FAQs

ArrowStream is working closely with distributors to set up new data feeds and collect crucial traceability information for Key Data Elements (KDEs) like expiration dates, delivery dates, pack dates, and lot codes. Our approach aligns with the distributors’ FSMA timeline, ensuring a smooth transition.

Through this, ArrowStream will ensure that operator invoice data is connected directly to the lot codes for items on the FTL (Food Traceability List). This significantly enhances food traceability yielding several key benefits:

  • Regulatory Compliance: Simplifies compliance with food safety laws and eases audit processes.
  • Faster Recall Response: Quickly locate and isolate affected batches during recalls to protect customers.
  • Supplier Accountability: Identify quality issues by batch, promoting consistent supplier quality.
  • Customer Transparency: Share ingredient origins, meeting demands for food sourcing transparency.

ArrowStream is centralizing all data and developing easy-to-use search tools for quick access. We’re also looking at ways to expand traceability coverage, giving you more visibility than the basic requirements.

No. The KDE’s require a separate data feed from your distributors to be pulled into ArrowStream.

No. The distributor relationships are owned by the operator brands and buying groups.

ArrowStream is working with your distributors now to obtain data files on deliveries from their warehouses to your stores.  Although we want to collect data quickly and accurately, we need your help. 

You are the distributor’s customer and maintain the most leverage in the relationship. As you have conversations with key suppliers and distributors that have foods on the Food Traceability List, ask what they are doing to prepare for FSMA 204.  Please share that you are working with ArrowStream to collect your data and ask them if they are actively sending data now. 

If you have any questions, please work with your account manager and we will help you get the answers you need.

Yes. ArrowStream can still work with the distributor on behalf of the brand.

ArrowStream can still setup connections with these distributors, although there may be extra costs associated with it.

Additional questions? Contact us.

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