As Jan. 20, 2026, nears for the enforcement of the Food Safety Final Rule of the Food Safety Modernization Act, Lucelena Angarita, director of food supply chain visibility at GS1 US, says it's never too early to start preparing a fresh produce business for this change.
Angarita joined the “Tip of the Iceberg” podcast to discuss FSMA 204, which dictates more record-keeping and requirements of high-risk foods throughout the fresh produce supply chain from grower to packer, both foreign and domestic.
While there might be some discussion of whether the Jan. 20, 2026, enforcement date will get pushed back, Angarita said this is still a critical time for fresh produce businesses to take action.
“Start understanding how the rule impacts your specific organization and what exemptions apply to your business," she said.
However, Angarita encourages businesses to not reinvent the wheel when it comes to finding ways to implement key data elements, or KDEs, and critical tracking events, or CTEs. GS1 US has resources to help produce industry businesses prepare for FSMA 204.
“This is something that is meant to be done within your supply chain network,” she said. “So, leverage others. Reach out to [GS1 US]; reach out to your peers [and] your trading partners and make sure you're understanding not just where your current state is, but where your network is and what are their expectations.”
Angarita said some companies and retailers may have additional requirements along with the FSMA 204 documentation.
“We're hearing this more and more as one of the major focus points, not just for the rule itself — because the rule doesn't really require unique identification or bar codes or anything like that — but the trading partners or your customers might be requiring these things because it does create all these operational efficiencies; it increases accuracy,” she said.
Angarita said FSMA is ultimately designed to enact recalls quicker and with less food waste, helping to find the origin of an issue faster and eliminating the product from the supply chain as quickly as possible.
"Yes, it's a lot of data that's being asked for, but I think understanding that at the heart of this is to help keep people safe, help better inform people and get the answers in terms of what products are recalled faster so that they're removed from that supply chain sooner and then hopefully sickening less people," she said.
by Christina Herrick, Mar 10, 2025