The more I learn about traceability implementation, the more I realize that no single segment of the supply chain can make traceability successful on its own; success depends on coordinated efforts from farm to fork.
Western Growers recently submitted comments highlighting a gap in the Traceability Rule involving entities that coordinate the movement of food but do not take physical possession of the product, such as brokers and certain intermediaries. While these entities may not be subject to the same traceability recordkeeping requirements, Western Growers believes clear expectations for their role in supporting traceback efforts and maintaining the integrity of traceability information throughout the supply chain are critical.
The importance of full-supply-chain accountability and investment is not merely theoretical. Recent outbreak investigations, including the 2025 Salmonella outbreak linked to imported mangoes, demonstrated that even if the FDA identified a strong epidemiological link to a common importer, the investigation was constrained by a lack of lot-level traceability, product commingling, and incomplete records. The lesson extends beyond regulatory compliance.
Successful traceability requires investment from all sectors of the supply chain. As fresh produce growers/shippers continue investing significant resources in systems, software, training, and data management to meet traceability requirements, investment is needed across all supply chain entities. Achieving the goal of the FDA’s Traceability Rule will require both accountability and investment throughout the supply chain. Every participant who contributes to the movement of food must also contribute to the integrity of traceability records.
Ultimately, the effectiveness of the traceability rule will depend not on strong isolated traceability systems, but on whether every link in the chain fulfills its responsibility.
To access WG’s story on traceability gaps, click here.
To register for a webinar on upcoming traceability pilots, click here.