Kroger Food Traceability Policy and Supplier Requirements
Enhanced traceability recordkeeping requirements for organizations that manufacture, process, pack, or hold food
Attention! Action Required for Contact Designation
Thank you to all suppliers who have already submitted their FSMA 204 compliance contact in response to our August 12 request.
If you have not yet designated a compliance contact for your organization, it is required that you do so immediately using the link below:
Submit Your Contact Nomination Form Here
This individual (or individuals) will serve as Kroger’s primary point of contact for critical program requirements, guidance, training invitations, and communications related to FSMA 204, Advance Shipping Notices (ASN), Electronic Data Interchange (EDI), and labeling updates. Please ensure the nominated contact has knowledge of your product specifications and traceability requirements or the ability to forward communications on these topics to the appropriate person/s.
Subject: Action Required by December 18; FSMA Item Declarations
October 2026
Dear Valued Kroger Supplier,
Thank you to everyone who submitted a traceability contact following our August request. This information helps Kroger send compliance requirements, training opportunities, and implementation updates to the appropriate contacts within your organization.
Food suppliers must now review the products they provide to Kroger and determine which items are included on the FDA Food Traceability List (FTL) as detailed within the Food Safety Modernization Act (FSMA). For each applicable item, complete the required FSMA self-declaration in the product’s information management platform; Salsify, Syndigo, or 1WS.
Complete declarations for existing applicable items by December 18, 2026. Beginning on that date, the required declaration must also be completed when setting up an applicable new item.
Remember: The FTL lists foods, not companies. Review each item separately based on its ingredients, formulation, form, processing, and any applicable exemptions. Kroger cannot determine whether an item is subject to the rule or whether an exemption applies on a supplier’s behalf.
Kroger will provide separate guidance on future ASN 856, EDI, labeling, testing, and implementation requirements. Do not make technical changes based on assumptions or requirements that Kroger has not formally communicated.
Required Actions
- Complete the FSMA self-declaration for each applicable item by December 18, 2026.
- Submit the required Contact Nomination Form if you have not already done so, or update your compliance contact’s information.
- Review the Kroger FSMA FAQ and available support resources in the Supplier Traceability Hub.
- Monitor Kroger communications for future ASN, EDI, labeling, testing, and training requirements.
- Register your interest in upcoming Kroger traceability pilots, webinars, town halls, and training opportunities.
Thank you for helping Kroger build accurate and dependable traceability across the supply chain.
Sincerely,
Howard Popoola
Vice President, Corporate Food Technology & Regulatory Compliance
The Kroger Co.
1014 Vine Street
Who Should Be Identified as a Contact?
The individual or individuals you provide will serve as Kroger’s points of contact for:
- Program requirements
- Guidance and training invitations
- Advance Shipping Notice (ASN) communications
- Electronic Data Interchange (EDI) communications
- Traceability updates
- Labeling updates
Contacts may include your corporate food safety lead, food technology lead, sales manager, or another individual with detailed knowledge of your product specifications, traceability requirements, and labeling processes.
Please ensure these individuals can either act on or appropriately forward communications related to these important matters.
FAQ
For extra opportunity to participate in Kroger’s Food Safety and Traceability Program, including pilot opportunities, news updates, and limited event invitations, please complete the form at this secure link.
What is FSMA (the Food and Safety Modernization Act)?
The Food Safety Modernization Act or FSMA is a food-safety law that applies to companies who make, handle, or sell food to consumers.
How does the Food Traceability Rule relate to FSMA?
The FDA issued the Food Traceability Rule (officially titled Requirements for Additional Traceability Records for Certain Foods) on November 21, 2022. The rule creates a consistent framework for recording specific information as foods move through the supply chain, requiring applicable businesses to maintain Key Data Elements (KDEs) for the Critical Tracking Events (CTEs) they perform. This data enables faster identification and removal of potentially dangerous foods within the supply chain.
When does Kroger expect supplier compliance of the Food Traceability Rule?
In order to ensure readiness before the FDA’s deadline, Kroger has a supplier compliance deadline of July 31, 2027.
When will the FDA begin enforcement of FSMA and the Food Traceability rule?
The FDA already enforces some requirements established under FSMA’s various implementing rules. For the Food Traceability Rule specifically, the FDA has stated a federal enforcement date of July 20, 2028. However, suppliers should not wait until then to prepare as Kroger is requiring supplier compliance by July 31, 2027.
Who does FSMA and the Food Traceability Rule apply to?
FSMA applies broadly to businesses that grow, manufacture, process, pack, hold, transport, or import food for consumption in the United States. Different FSMA rules apply to different activities, and some businesses, foods, and activities qualify for full or partial exemptions.
The Food Traceability Rule specifically applies to persons who manufacture, process, pack, or hold foods on the Food Traceability List, unless an exemption applies. Suppliers must evaluate each food and activity separately based on the rule’s requirements, see more below.
Understanding the Food Traceability List (FTL)
What is the Food Traceability List (FTL)?
The Food Traceability List (FTL) is the list of foods defined by the FDA as subject to additional recordkeeping requirements. It includes the foods named on the list, as well as foods containing an FTL food as an ingredient. All ingredients and processing steps must be considered when making a food’s FTL determination.
How do I determine if my company or products are subject to the rule?
Foods are listed on the FDA Food Traceability List (FTL), not companies. Each item should be evaluated individually based on its ingredients, characteristics, processing, and any applicable exemptions.
Suppliers are responsible for determining whether their products are subject to the rule. FDA guidance and support resources, including the FDA’s Technical Assistance Network (TAN), are available to help with questions or complex scenarios.
When evaluating an item, consider:
- Product information
- Ingredients and components
- Product form (for example, fresh, frozen, refrigerated, or shelf-stable)
- Processing methods applied to the product
- Whether processing changes the nature or classification of the food
- Food Traceability List applicability
- Review the current FDA Food Traceability List and associated guidance.
- Assess whether the product or its ingredients fall within the scope of any listed food categories.
- Exemptions and special considerations
- Review FDA guidance regarding exemptions, partial exemptions, and processing activities that may affect traceability requirements.
- Certain processing steps, including validated pathogen reduction processes, may impact whether a food remains subject to FTL requirements.
- Supporting documentation
- Maintain records supporting your determination and any assumptions, analyses, or documentation used in reaching it. Kroger does not evaluate, receive, or hold this documentation but it may be required in the event of an incident, recall, or FDA records request.
- Supplier declarations
- Declare the FSMA status of all food items provided to Kroger Co. within its attributes in Salsify or Syndigo.
Note: This information is provided as a general overview and is not regulatory or legal advice. Suppliers are responsible for evaluating their products and ensuring compliance with applicable FDA requirements.
How does the “form” of the food or “processing” affect FTL status?
Some foods appear on the FTL only in specifically identified forms (e.g., fresh, fresh-cut, frozen). A food included only in its fresh form may no longer be on the FTL after it is frozen or dried. However, this does not apply equally to every food and you should not assume that any processing activity automatically removes the food from the FTL.
Are multi-ingredient foods included on the FTL?
A multi-ingredient food is included when it contains an FTL ingredient and no kill-step exemption applies. A product is not excluded automatically when the ingredient statement does not explicitly name the FTL food category (for example, a product may contain peanut butter even when its component ingredients are declared individually). Evaluate the actual product formulation, not just the label.
What should I do if I am unsure whether a product is on the FTL?
Kroger cannot make a supplier’s regulatory scope or exemption determination. If you are uncertain after reviewing the FDA’s FTL descriptions and FAQs, do not guess. Consult your company’s food safety, regulatory, compliance, or legal representative. If the determination remains unclear, submit your question directly to the FSMA Technical Assistance Network (TAN).
Kroger Suppliers: Next Steps
What action do Kroger suppliers need to take right now?
Suppliers will need to review the products they provide to Kroger and for each, make a determination on the item’s FSMA FTL status. They must then update item attributes within Salsify or Syndigo.
When must suppliers complete their item updates for FSMA declaration?
November 25, 2026 is the deadline for suppliers to complete the required updates for all food items. Beginning November 25, 2026, the required FSMA 204 information must also be provided when setting up applicable new items in Salsify or Syndigo.
Are any Advance Shipping Notice (ASN), labeling, or Electronic Document Interchange changes required now?
Not yet. Kroger will provide additional information regarding Advance Shipping Notice (ASN) requirements, labeling requirements, Electronic Data Interchange (EDI) platform options, implementation dates, and testing activities at a later date. Suppliers should not assume specific technical requirements until receiving Kroger-approved guidance.
What support will be available to suppliers?
Information will be forthcoming on Kroger plans to provide supplier support through:
- A dedicated support mailbox: FoodTraceability@Kroger.com
- Salsify and Syndigo support sites
- FSMA Technical Assistance Network (TAN): A contact portal where industry professionals can submit specific, complex regulatory questions directly to FDA experts.
To join our mailing list for FSMA 204 pilot opportunities, news updates, and event invitations, please complete the form at this secure link.
Glossary
Term or acronym | Full name | Definition |
204, FSMA 204 | Section 204 of FSMA | The section of FSMA addressing enhanced tracking, tracing, and recordkeeping for certain foods. |
ASN | Advance Shipping Notice | An electronic message sent before a shipment arrives. It may communicate products, quantities, lot codes, and other shipping information. |
Commingled RAC | Commingled Raw Agricultural Commodity | A qualifying non-produce RAC combined or mixed after harvesting but before processing. Specific requirements apply, including conditions related to different farms or landing vessels. |
Covered entity | — | An informal term for a person or business subject to applicable requirements of the Food Traceability Rule. |
Covered food | — | An informal term for a food subject to applicable Food Traceability Rule requirements. Whether requirements apply may depend on the food, its form, processing, and any exemption. |
CTE | Critical Tracking Event | A supply-chain event for which specific traceability information must be recorded. CTEs include harvesting, cooling before initial packing, initial packing, first land-based receiving, shipping, receiving, and transformation. |
EDI | Electronic Data Interchange | A standardized method for computer systems to exchange business records, such as purchase orders, invoices, and ASNs. |
Exemption | — | A provision under which specified Food Traceability Rule requirements do not apply to a food, person, or activity. |
FDA | U.S. Food and Drug Administration | The federal agency responsible for administering and enforcing many U.S. food-safety requirements, including the FSMA rules. |
FLBR | First Land-Based Receiver | The person who first takes possession of a food on land directly from a fishing vessel. The FLBR generally assigns the Traceability Lot Code (TLC) for that food. |
FSMA | FDA Food Safety Modernization Act | A U.S. food-safety law focused on preventing food-safety problems rather than responding only after they occur. |
FSPCA | Food Safety Preventive Controls Alliance | A public-private alliance that develops food-safety training and technical materials in cooperation with FDA and other stakeholders. |
FSVP | Foreign Supplier Verification Program | A FSMA program requiring covered importers to perform risk-based activities to verify that foreign suppliers produce food consistent with applicable U.S. food-safety requirements. |
FTL | Food Traceability List | FDA’s list of foods subject to additional traceability recordkeeping requirements. Foods, not companies, are on the FTL. |
FTL food | Food Traceability List food | A food that fits a category and description on the FTL. This may include a specifically listed food or a food containing an FTL ingredient that remains in its listed form. |
GLN | Global Location Number | A standardized number used to identify a business or physical location. It may represent a location description if FDA can access all required information through it. |
GTIN | Global Trade Item Number | A standardized number used to identify a specific trade item or product. A GTIN is not automatically a Traceability Lot Code (TLC). |
Initial packing | — | Packing a Raw Agricultural Commodity (RAC), other than food obtained from a fishing vessel, for the first time. This is generally when the initial packer assigns the Traceability Lot Code (TLC). |
Internal lot code | — | A code a company uses for its own inventory or production tracking. If it differs from the Traceability Lot Code (TLC), the required TLC must still be maintained and provided when applicable. |
KDE | Key Data Element | Information associated with a CTE that must be maintained or provided. Examples include dates, quantities, product descriptions, location descriptions, and TLCs. |
Kill step | — | Processing that significantly minimizes pathogens in a food. Examples may include cooking, pasteurization, irradiation, or high-pressure processing when the process achieves the appropriate lethality. |
Lot linking | — | Connecting incoming Food Traceability List (FTL) food Traceability Lot Codes (TLCs) to the TLC assigned to a food produced through transformation. This allows the ingredients and finished product to be traced together. |
Partial exemption | — | A provision that removes some requirements but leaves other requirements in place. |
PCHF | Preventive Controls for Human Food | FSMA requirements covering current good manufacturing practices, hazard analysis, risk-based preventive controls, and related requirements for covered human-food facilities. |
PSR | Produce Safety Rule | The FSMA rule establishing science-based minimum standards for growing, harvesting, packing, and holding covered produce. |
RAC | Raw Agricultural Commodity | A food in its raw or natural state, such as produce, shell eggs, or certain aquacultured foods, before processing changes its general state. |
SSCC | Serial Shipping Container Code | A standardized number used to identify a logistics unit, such as a pallet. It may be linked to information describing the pallet’s contents. |
TAN | FSMA Technical Assistance Network | An FDA resource for questions about FSMA rules, programs, and implementation. |
TLC | Traceability Lot Code | A code, often containing letters and numbers, used to uniquely identify a traceability lot within the Traceability Lot Code (TLC) source’s records. |
TLC source | Traceability Lot Code Source | The physical location where the Traceability Lot Code (TLC) was assigned to the food. It is not automatically the company’s headquarters, billing location, or brand owner. |
TLC source reference | Traceability Lot Code Source Reference | An alternative way to give FDA access to the location description of the Traceability Lot Code (TLC) source. Examples may include an FDA Food Facility Registration Number, a Global Location Number, or a web address. |
Traceability lot | — | A batch or lot of food that has been initially packed, received by the first land-based receiver, or produced through transformation. |
Traceability plan | — | A required document explaining how a covered business identifies FTL foods, maintains required records, assigns TLCs when applicable, and identifies a point of contact. Certain farms must also include a farm map. |
FDA Resources & Links
Background and Overview
Use the following official FDA resources to understand the rule, determine your status, and build your traceability program:
The Food Traceability List (FTL): A comprehensive list of the specific foods subject to the traceability recordkeeping requirements.
Critical Tracking Events (CTEs) and Key Data Elements (KDEs): A guide detailing the stages of the supply chain and data points that must be recorded and passed along at each stage.
Traceability Lot Code (TLC): An explanation of what a TLC is, who is responsible for assigning it, and how it must be linked to the product.
Traceability Plan Requirements: Outlines the requirement to establish and maintain a written Traceability Plan.
Federal Register Notice (The Final Rule Text): The official, published legal text of the regulation, including the FDA’s responses to public comments.
Exemptions to the Food Traceability Rule (and Exemption Tool): A breakdown of partial and full exemptions to the rule, featuring an interactive tool to help businesses determine their status.
Supply Chain Examples: Visual diagrams and step-by-step scenarios showing how the rule applies to different types of supply chains.
FDA’s Frequently Asked Questions (FAQs): The FDA’s official answers to common industry questions regarding compliance, definitions, and enforcement.
Kroger Tool Support:
Support & Multimedia
FSMA Technical Assistance Network (TAN): A contact portal where industry professionals can submit specific, complex regulatory questions directly to FDA experts.
FDA Guidance for Industry: Small Entity Compliance Guide
Food Traceability Videos, Webinars, and Fact Sheets: A collection of multimedia resources, downloadable PDFs, and past FDA presentations explaining the rule in plain language.
Industry Training from the Food Safety Preventative Control Alliance: Curriculum for firms that manufacture, process, pack, or hold FTL foods and must comply with the Food Traceability Rule.
Contact Support
Please send questions regarding Kroger Food Track & Trace product receiving specifications to FoodTraceability@kroger.com.