The FDA doesn’t wait for hundreds of people to get sick before acting. When a foodborne illness outbreak hits, time is everything. A single contaminated batch of spinach or peanut butter can spread across dozens of states in days. That’s where lot number tracking becomes the difference between a contained incident and a nationwide crisis.
What Is a Traceability Lot Code (TLC)?
A traceability lot code (TLC) is a unique identifier - usually a mix of letters and numbers - assigned to a specific group of food products at key points in the supply chain. It’s not just any lot number you might see on a jar of peanut butter or a bag of lettuce. This is a government-mandated system designed to trace food from farm to table in hours, not weeks. The TLC is the core of the FDA’s Food Traceability Rule, part of the Food Safety Modernization Act (FSMA) finalized in November 2022. It applies to foods on the Food Traceability List (FTL), which includes high-risk items like leafy greens, tomatoes, onions, fresh-cut fruits and vegetables, certain cheeses, eggs, nut butters, and specific seafood. These foods make up about 15% of the U.S. food supply but are linked to the majority of foodborne outbreaks. Unlike old-style lot codes, which companies used internally for quality control, the TLC must be passed along every step of the way. Once assigned, it stays with the product unless the food is transformed - say, when raw tomatoes are turned into salsa. At that point, a new TLC is created, but it must still link back to the original.How the FDA Uses TLCs to Track Contamination
When someone gets sick from contaminated food, public health officials start asking: Where did this come from? Which batch? When was it packed? Who shipped it? Before the TLC system, investigators had to call dozens of companies, dig through paper records, and piece together shipping logs. It could take weeks. Now, if the FDA requests data during an outbreak, companies must provide all seven Key Data Elements (KDEs) linked to the TLC within 24 hours. These include:- The traceability lot code itself
- Where and when the code was assigned
- Product description
- Quantity and unit of measure
- Transaction information (who sent it, who received it)
- Location of each handling event
- Any previous TLCs the product came from
Where and When TLCs Are Assigned
You can’t just slap a TLC on a product whenever you want. The FDA requires it to be assigned at three specific points:- When raw agricultural commodities (like lettuce or onions) are first packed - except for seafood from fishing vessels.
- When seafood from fishing vessels is received on land for the first time.
- When food is transformed - meaning its physical state changes, like when eggs are turned into liquid egg product or nuts are ground into butter.
Flexibility in Code Design - But No Room for Error
The FDA doesn’t dictate what the TLC looks like. A company can use a Julian date + product code (like “2025045-LG12”), a random alphanumeric string, or even their existing internal lot code - as long as it’s unique and traceable. But here’s the catch: the code must be usable across the entire supply chain. A code that works for one company’s warehouse might not be readable by a distributor’s system. That’s why the FDA encourages electronic records in formats like CSV or JSON, which can be easily shared and searched. Many large companies have already upgraded their ERP systems to handle TLCs. Smaller farms and processors are using simpler tools - even spreadsheets - as long as they can produce the required data on demand. The FDA offers free training modules and technical help through its Traceability Assistance Program for small businesses.Why This System Is a Game-Changer
The old system was like trying to find a needle in a haystack while blindfolded. The TLC system turns that into a GPS search. The FDA estimates that faster traceability could reduce foodborne illness outbreaks by 20-30%. That’s tens of thousands of fewer sick people every year. In pilot programs from 2019 to 2021, companies using TLCs were able to trace contaminated products in under 24 hours - compared to 7-14 days before. Retailers like Walmart and Kroger have gone even further, using blockchain to track leafy greens in real time. But the TLC system is the baseline - the minimum standard that every food handler must meet.
Challenges and Criticisms
It’s not perfect. Some companies complain about “tandem coding” - having to maintain both their internal lot codes and the new TLCs. But the FDA clarified early on: your existing code can be your TLC, as long as it meets the rules. Others argue the Food Traceability List is too narrow. Melons, for example, have been linked to outbreaks but aren’t included yet. Consumers Union and other groups say that’s a dangerous gap. The FDA agrees - Commissioner Robert Califf has said melons and ready-to-eat foods are under active review for inclusion. Another issue: interoperability. If one company uses a barcode, another uses a QR code, and a third uses a manual log, data can get stuck in silos. The FDA is working on standardized electronic formats, with a draft expected in mid-2024.Compliance Timeline and Real-World Impact
The rule became effective in December 2022, but companies had until January 20, 2026, to comply. In September 2023, the FDA proposed pushing that deadline to July 20, 2028 - a 30-month extension - after hearing from small businesses that they needed more time. As of early 2025, about 78% of larger produce companies have already adjusted their systems. But only 42% of small and medium businesses know the requirements exist. That’s why the FDA is ramping up outreach, and why the 2023 Farm Bill included $25 million in grants to help small farms implement TLC systems. The market for food traceability tech is booming - projected to grow from $1.87 billion in 2022 to over $4.6 billion by 2028. That growth isn’t just about compliance. It’s about trust. Consumers want to know their food is safe. Retailers want to avoid recalls. And the FDA wants to stop outbreaks before they spread.What This Means for You
If you buy fresh produce, eggs, or nut butter, this system protects you. When a recall happens, you’ll see it faster. The affected lot numbers will be published quickly because the FDA can pinpoint them in hours, not days. You might not see the TLC on your package - it’s often buried in shipping documents or digital records. But it’s there. And when something goes wrong, it’s the reason the FDA can act before you or your family get sick. This isn’t just bureaucracy. It’s a safety net woven into the food supply - one lot code at a time.What is a traceability lot code (TLC)?
A traceability lot code (TLC) is a unique alphanumeric identifier assigned to a specific batch of food on the FDA’s Food Traceability List. It must be passed along the supply chain and linked to seven key data elements so the FDA can trace contaminated food back to its source within 24 hours during an outbreak.
Which foods require lot number tracking under FDA rules?
Foods on the FDA’s Food Traceability List (FTL) require TLCs. This includes leafy greens, tomatoes, onions, fresh-cut fruits and vegetables, certain cheeses, eggs, nut butters, and specific seafood products. These represent about 15% of the U.S. food supply by volume and are linked to the majority of foodborne illness outbreaks.
When do companies have to start using traceability lot codes?
The original compliance date was January 20, 2026. However, in September 2023, the FDA proposed extending this deadline to July 20, 2028, to give small businesses more time. This extension is pending final approval but is widely expected to be finalized.
Can a company use its existing lot code as the TLC?
Yes. The FDA explicitly allows companies to use their existing internal lot codes as the traceability lot code, as long as the code is unique, consistently applied, and passed along with the product through the supply chain. There’s no need to create a second code unless the existing one doesn’t meet the required standards.
Why isn’t melon on the FDA’s Food Traceability List?
Melons were not included in the initial Food Traceability List, despite being linked to past outbreaks. Critics argue this creates a dangerous gap. The FDA has stated that melons and certain ready-to-eat foods are under active review for future inclusion. A decision is expected in 2025 or 2026 based on outbreak data and risk analysis.
Jennifer Shannon
Wow, this is actually one of those rare government regulations that makes perfect sense-like, who knew a bunch of letters and numbers on a shipping label could be the difference between your kid eating dinner and ending up in the ER? I’ve been buying organic spinach for years without ever thinking about where it came from, but now I’m kinda glad someone’s keeping track. It’s not glamorous, but this is public health infrastructure at its quietest, most vital best.
Henrik Stacke
As someone who’s worked in UK food logistics, I can tell you this system is revolutionary. We’ve had recalls where we spent weeks chasing down batches-paper forms, faxed invoices, phone calls to distributors who’d retired. The FDA’s approach is not just smart-it’s humane. It saves lives, yes, but it also saves small businesses from the reputational carnage of a blind recall. Kudos to the regulators for getting this right.
Dalton Adams
Let’s be real-this is just corporate compliance dressed up as public safety. You think Walmart’s blockchain thing is about trust? Nah, it’s about liability. The FDA didn’t invent this out of altruism-they got sued too many times. And don’t get me started on the 2028 deadline extension. That’s not compassion, that’s industry lobbying winning again. The system’s fine, but the motives? Not so pure. 🤷♂️
Bryson Carroll
This is why I hate food regulation-overcomplicated, under-enforced, and full of buzzwords. TLC? KDEs? Who talks like this? And why do we need seven data elements just to trace a bag of lettuce? I’ve seen farms with 3 employees using Excel sheets and they’re fine. This is bureaucracy for bureaucracy’s sake. And don’t even get me started on the cost to small producers
Manjistha Roy
As someone from India where food traceability is still a dream, I find this system deeply inspiring. In our markets, we still rely on handwritten labels and oral agreements-when something goes wrong, there’s no trail, just grief. This isn’t just about safety-it’s about dignity. Every farmer, every worker, every consumer deserves to know where their food came from. Thank you for making this visible.
Kane Ren
I used to think food safety was just about inspections and clean kitchens-but this? This is next-level. It’s like GPS for your grocery bag. Imagine if every product we bought came with a digital story-where it grew, who picked it, how it traveled. This isn’t just regulation, it’s storytelling with purpose. And honestly? I feel safer already.
Richard Wöhrl
One thing missing from the article: the role of third-party auditors. The FDA doesn’t have the manpower to verify every TLC submission-so they rely on accredited third parties to validate data integrity. These are often private firms with certifications like GFSI or SQF. Without them, the system collapses under its own weight. Also, many small farms are using QR codes linked to Google Sheets-simple, but effective. The tech isn’t fancy, but the intent is.
JD Mette
I read this and just felt… relieved. Not excited, not outraged-just relieved. Like, finally, someone’s doing something that actually works. I don’t need to understand all the jargon. I just need to know that if I get sick from a bag of spinach, the people in charge won’t be guessing. That’s enough for me.
Olanrewaju Jeph
This is an exemplary model of regulatory design-precise, scalable, and grounded in empirical risk assessment. The inclusion of transformation points as critical junctures for reassignment is particularly elegant, as it prevents data fragmentation during processing. Furthermore, the allowance for legacy lot codes as compliant TLCs demonstrates a pragmatic understanding of operational realities. This is how policy should be crafted: not by fiat, but by collaboration.
Kezia Katherine Lewis
What’s interesting is how this system redefines accountability. Before, responsibility was diffuse-everyone blamed someone else. Now, the TLC creates a chain of custody that’s legally binding. It’s not just about tracing food-it’s about tracing human decisions. Who approved the harvest? Who signed off on the shipment? Who failed to update the digital log? The code doesn’t lie. And that’s terrifying… in the best way.
Pramod Kumar
I’ve seen this play out in small Indian spice mills-when a batch gets contaminated, they lose everything. No traceability means no second chances. This FDA system? It’s not just American-it’s universal. The same logic could save lives in Lagos, Jakarta, or Lima. The real win isn’t the tech-it’s the mindset: if you can’t trace it, you shouldn’t sell it. Simple. Powerful. Necessary.
Jennifer Skolney
My dad runs a small egg farm. He’s terrified of this rule. But I showed him the FDA’s free training videos-and now he’s using a $15 QR code generator on his phone. He says, ‘If this keeps one family from getting sick, it’s worth it.’ I cried. 🥺