Since the November 2022 release of the U.S. Food and Drug Administration's (FDA's) final rule on Requirements for Additional Traceability Records for Certain Foods, food industry actors have been working to interpret the rule requirements in preparation for compliance in January 2026.Although each component of the rule will drive impactful changes in the food industry, one component stands out—the Traceability Lot Code (TLC).
A code used to identify a specific "lot" or "batch" of product, the TLC is the most important Key Data Element (KDE) required by the rule because it links a food product to each of the events in its supply chain. The limited circumstances under which TLCs can be assigned and the persistent connection to the TLC Source (the entity that assigned the TLC) arekey components of the TLC requirements.These requirements aim to enable more efficient outbreak investigations and product containment efforts.Several comments on the draft rule suggested that the TLC requirement is unnecessary given that PO numbers, BOLs, and other commonly used reference documents provide sufficient documentation to link products back to their point of harvest, creation, or transformation.