Much has already been written about the FDA’s proposed 30-month delay of the Food Safety Modernization Act (FSMA) Rule 204 for enhanced traceability— but instead of racing to react, I chose to listen, discuss, and reflect. Over the last several weeks, I’ve spoken with clients and colleagues to better understand the implications of this announcement—not just legally, but practically.

Let’s start with a key fact: the delay has not yet been finalized. While the industry is widely treating the January 2026 compliance date as postponed, it hasn’t gone through formal rulemaking. That uncertainty matters. Still, from what I’m hearing, many in the industry are breathing a temporary sigh of relief, especially those still grappling with details of implementation.

Two Camps Have Emerged…

In talking with food companies, tech vendors, and supply chain partners at recent conferences, two distinct approaches have become clear:

Camp One: Let’s keep going!

These organizations view enhanced traceability as essential, not just for compliance, but for operational excellence. They remain focused on progress, regardless of the proposed regulatory delay.

Why they’re staying the course:

· The delay isn’t final. Delaying action could create a crunch later.

· The additional time provides breathing room and allows for clarification of open questions and the ability to “get it right”.

· Key retail partners are still pushing for the original timeline.

· Traceability insights can drive real business value- from recalls to inventory control.

· Being an advocate for traceability makes their organization market leaders.

Camp Two- We’ll come back to this later!

A significant portion of the industry has pressed pause. These companies acknowledge the value of traceability but are diverting attention to what they see as more immediate priorities.

Why they’re hitting pause:

· Cost and complexity remain major concerns.

· Lack of supply chain interoperability is still a barrier.

· Uncertainty around the final rule has made planning and commitment difficult.

· Competing priorities, such as cost-cutting, or reformulation of artificial dyes and colors have become critical tasks of recent. 

· Their customers aren’t demanding traceability data- yet. 

What Should You Do?

There are valid arguments on both sides, and here’s what I’ve been advising clients:
Take a measured, balanced, and strategic approach. Use this time not to delay, but to strengthen your foundation. Keep FSMA 204 a priority—but aim to do it right, not just fast.

Still unsure?  Consider these next steps:

Build cross-functional ownership- bring together teams from food safety, operations, IT, and marketing to ensure alignment so that your efforts remain visible and a company priority. 

Engage your supply chain- define what data you need and begin collecting it so that you can identify gaps and close them.

Understand the full cost- identify smart investments now to reduce long-term traceability costs

Update the roadmap- maintain momentum while adjusting timelines for other priorities such as reformulation. 

Test the system- use this extended window to try, learn, and ideate before your full-scale rollout.

Every significant journey begins with a single step. FSMA 204 will require effort, but early action will pay off in compliance readiness and tangible business value. 

Still unsure where to begin? At Schneider Food Safety Services, we specialize in helping organizations of all sizes navigate FSMA 204 compliance. From developing tailored roadmaps to addressing your unique challenges, we’re here to guide you every step of the way. Contact us today to ensure a smooth journey to compliance!