Unpacking the FSMA Rule 204 Extension Proposal

The FDA proposes a 30-month extension to the FSMA Rule 204 compliance deadline, moving it to July 20, 2028. What does this mean for restaurant operators? To understand the current landscape and what operators need to do to prepare, Modern Restaurant Management (MRM) magazine reached out to Jeff Cowan, Senior Director of Customer Success at GS1 US, the  neutral, not-for-profit standards organization. For additional background on the topic, read Cowan's FSMA Rule 204 Food Safety Countdown: What Restaurant Managers Need to Know Now.

What is the current status of FSMA Rule 204 implementation and what are the reasons around the call for a 30-month extension?

FSMA Rule 204 — the FDA’s Food Traceability Rule — officially took effect November 21, 2022 with an original compliance date of January 20, 2026. In late July, the FDA proposed a 30-month extension, which would move that date to July 20, 2028. The extension was proposed in recognition that meeting the requirements is a big lift for the entire food supply chain. Restaurants, manufacturers and distributors are being asked to capture and share very specific traceability data — specifically Key Data Elements (KDEs) — at Critical Tracking Events (CTEs) such as shipping, receiving and transformation.

The proposed extension is the FDA acknowledging that affected organizations need more time to get the right systems, processes and training in place so the rule can be implemented effectively. However, the extension isn’t a free pass to delay progress given that meeting key requirements takes time and effort.

If the extension goes through, why should restaurant owners still prioritize preparations, rather than delaying efforts? And what should they be doing to prepare?

An extension just changes the requirement date. If you wait until the new date is looming, you’ll be competing with everyone else for resources such as technology, training, and vendor support, which can lead to higher costs, longer lead times and greater implementation challenges. Starting now means you can spread costs out, test systems without pressure and make changes in a thoughtful way. 

The proposed extension is the FDA acknowledging that affected organizations need more time to get the right systems, processes and training in place so the rule can be implemented effectively.

Restaurants can start preparing by mapping your current supply chain to identify exactly where traceability data will need to be captured. Have conversations with your distributors about their readiness and ability to share information. Explore systems that can store and share standardized, digital records and start training your staff in phases so it feels like a natural part of operations, not a sudden fire drill.

What can restaurant operators do to learn more about how FSMA affects their operations?

First, go to the source — the FDA’s FSMA Rule 204  page is the best place to see the rule itself, the Food Traceability List, and official guidance. Then, lean on your industry associations and trusted partners for “plain English” explanations. At GS1 US, we break down what’s required into manageable steps, with examples that make sense for restaurant operations. Resources are available at GS1US.ORG/FSMA and don’t underestimate the power of simply talking to your suppliers. Ask: “Which of my menu items are on the Food Traceability List? What data can you provide today?” Those conversations are often the most effective way to identify gaps and opportunities.

How can restaurant operators effectively leverage the resources and guidance from organizations like GS1 US to ensure compliance with the rule, even with the extended deadline?

Our mission at GS1 US is to make it easier for businesses to speak the same “data language” so information flows smoothly across the entire supply chain. For FSMA Rule 204, that means using GS1 Standards to meet the FDA’s KDE and CTE requirements in a consistent, digital format. The Global Trade Item Number (GTIN) uniquely identifies products, and the Global Location Number (GLN) uniquely identifies locations in the supply chain. Pairing these identifiers with the GS1 Standard, Electronic Product Code Information Services (EPCIS), event data creates a complete, interoperable record of your food’s journey. EPCIS enables the capture and sharing of supply chain event data to provide end-to-end visibility and traceability of products. It’s important to note that every solution to record FSMA Rule 204 data does not need to be digital; manually recording and sharing data is acceptable. The Rule is focused on the data, not the method. 

However, the extension isn’t a free pass to delay progress given that meeting key requirements takes time and effort.

We’ve created FSMA Rule 204-specific resources, including implementation guides, toolkits and industry workgroup insights that walk through the how-to. Even with an extension, leveraging existing standardized framework that may be in place now gives you a solid foundation for the rule — and honestly, it will also make your operations run more efficiently across the board.

What are the potential financial or operational risks for restaurant operators who play the waiting game?

The risk is ending up in a last-minute scramble and potentially spend more, get less support and make more mistakes. Technology providers and trainers will be inundated when the new date gets close. Operationally, rushing implementation can mean errors that affect ordering, receiving and recordkeeping. If a food safety incident happens and you can’t produce the required data within 24 hours to the FDA, you may be looking at potential closures, more product loss, all resulting in damage to your brand. 

Damage to the brand can be real. A recent survey commissioned by GS1 US found that 60 percent of consumers say they have avoided an entire food category, such as lettuce, following a recall.  That same survey found that 59 percent report hesitancy to purchase the same product or brand again after a food recall – especially millennials (65 percent) and Gen Z (64 percent) compared to baby boomers (53 percent). 

Beyond compliance, how can restaurant operators strategically use enhanced traceability to improve overall operations, strengthen food safety protocols, and build greater consumer trust?

This is where the benefits multiply. With better visibility into your supply chain, you can see exactly where your ingredients come from, which suppliers consistently deliver quality, and where there might be waste or inefficiency. That means smarter ordering, less spoilage, and more consistent quality for your guests. And when diners know you can trace their meal back to its source, it builds trust. In today’s competitive market, that trust is worth its weight in gold.