FDA Food Traceability Rule: Which Restaurants Are Actually Affected & How to Prepare

The FDA has extended the Food Traceability Rule 204 under the Food Safety Modernization Act (FSMA). Originally going into effect early 2026, the enforcement has been officially extended to July 2028. While this rule has generated concern across the restaurant industry, it’s important to clarify up front:

Which Restaurants Are Impacted by the Rule?

The Food Traceability Rule generally applies to food businesses that manufacture, process, pack, or hold certain high-risk foods outside of a traditional retail restaurant model.

Restaurants most likely to be affected include:

• Central kitchens or commissaries that prepare food for multiple restaurant locations.
• Restaurants that distribute food to other businesses, institutions, or third parties.
• Operations that manufacture packaged food products (sauces, dips, prepared meals) for wholesale or retail sales.
• Hybrid businesses acting as both a restaurant and a food manufacturer or distributor.

In these cases, the FDA may treat part of the operation more like a food processor or manufacturer, triggering additional recordkeeping requirements.

Does Rule 204 Apply to Your Restaurant? Here’s What to Know About Exemptions.

Rule 204 potentially impacts the following types of restaurant operations:

Retail Food Establishments (RFEs) including:

1. Full-service restaurants
2. Bars and restaurants serving food directly to guests
3. Quick-service and fast-casual restaurants
4. Cafés, bakeries, and food trucks
5. Restaurants selling meals directly to consumers (including via delivery apps)

Under FDA Rule 204, RFEs and restaurants that handle foods on the FDA’s Food Traceability List are generally subject to the rule unless a specific exemption applies. One key exemption is the small-operator threshold: The rule does not apply to establishments with an average annual monetary value of food sold or provided of $250,000 or less (based on a 3-year rolling average, inflation-adjusted). There is also a separate threshold at $1,000,000 or less under which establishments are exempt from providing the FDA with an electronic sortable spreadsheet, though they must still maintain the required records.

Based on conversations with national restaurant associations and industry guidance, most established operators exceed the small-operator threshold and to be safe, should plan as if they are covered. Because eligibility depends on both your revenue and how your operation is structured, this is not something to assume one way or the other. A quick review with a trusted food safety or regulatory advisor can confirm where you stand and prevent misclassification.

Why This Still Matters — Even If You’re Exempt

While many restaurants are exempt from new traceability records, the FDA’s direction is clear: Expectations around food visibility and documentation are increasing.

During a foodborne illness investigation or recall, restaurants may still be asked:

1. Where an ingredient came from
2. When it was received
3. How it was handled

Operators who can answer these questions quickly will face far less disruption.

5 Best Practices for Food Traceability All Restaurants Should Start Now

Whether exempt or covered, the following operational improvements will position restaurants well for 2026 and beyond:

1. Strengthen Receiving Procedures

• Make sure all deliveries are received by trained staff.
• Verify vendor, product, and date on invoices.
• Store receiving records consistently (digitally if possible).

2. Organize Supplier Documentation

• Retain invoices and packing slips for high-risk foods such as seafood and produce.
• Know which vendors supply which ingredients.
• Confirm that suppliers are prepared to provide traceability data if requested.

3. Understand Your High-Risk Ingredients

• Review of the FDA Food Traceability List (FTL).
• Identify menu items that rely on those ingredients.
• Check that managers know where those items are sourced.

4. Evaluate Systems, Not Just Paper

• Inventory, AP, and vendor portals should allow easy record retrieval.
• POS and back-office systems should align with how food is received and tracked.
• Avoid scattered documentation across email, binders, and desktops.

5. Train Managers, Not Just Back Office

• Traceability should be part of operational awareness.
• Managers should know what information to pull if asked by regulators.
• Consistency matters more than perfection.

Key Takeaway for Restaurant Operators

The FDA Food Traceability Rule is not a blanket mandate on restaurants — but it is a signal.

Restaurants operating central kitchens, commissaries, or food manufacturing functions should begin compliance planning now. All other operators should treat this as an opportunity to tighten receiving, documentation, and supplier communication before enforcement begins.

Preparation today reduces risk, disruption, and stress tomorrow.