Timeline
| Date | Milestone |
|---|---|
| Jan 20, 2026 | Original compliance date |
| 2025-2026 | FDA proposes 30-month extension; Congress directs non-enforcement before Jul 20, 2028; FDA says it intends to comply |
| Jul 20, 2028 | Earliest enforcement date |
A realistic plan for the extra time
- Now
Confirm which of your products are on the Food Traceability List.
- 2026-2027
Select or upgrade your ERP/traceability system; implementations take months, not weeks.
- Before mid-2028
Run mock 24-hour spreadsheet requests with suppliers and customers.
Turn this estimate into 3 real quotes
Published and benchmark prices are a starting point. Written quotes from independent partners are what you budget on.
Independence and disclosure. ERP Cost Guide is independent and is not a partner, reseller or affiliate of any ERP vendor. Buyers pay nothing. If we introduce you to an implementation partner, that partner may pay us a referral fee - see how we make money.
Frequently asked questions
Was FSMA 204 delayed?
Yes. FDA will not enforce it before July 20, 2028 (FDA page updated July 2026).
Sources
- FDA - FSMA Final Rule on Requirements for Additional Traceability Records (accessed 2026-09-23) - Source date: 2026-07-24