FSMA 204 Readiness Hinges on Moving Past Paper Logs and Disconnected ERPs

While simplified tools help fresh produce businesses ditch paper records, show floor discussions at the Global Produce & Floral Show highlight a lingering readiness gap with systems that still can’t connect to share data.

GS1 US team members at IFPA Global Produce Show promoting Rapid Record digital tracking tool using GTINs and GLNs for FSMA 204 compliance
The GS1-US team including David Linton, Pete Lovaglio, Damian Rosario, Randie Stone, Mike Fabrizio, Lucy Angarita, Liz Coan, Liz Sertl, Amanda Brown, Amy Behm, Patrick Javick, and Adam Daniels at the IFPA Global Produce & Floral Show. Sertl and Daniels highlighted GS1-US’s free Rapid Record tool, designed to help fresh produce businesses move from manual paper records to standardized GTIN and GLN digital tracking.
(Photo courtesy of GS1-US)

ORLANDO, Fla. — While at the GS1-US booth at the International Fresh Produce Association’s Global Produce & Floral Show, a lot of the conversation about the FDA’s Food Safety Modernization Act (FSMA) Rule 204 revolved around how it impacts different parts of the business.

The non-profit highlighted its Rapid Record, which is free and designed to help fresh produce businesses with FSMA 204 record keeping. It establishes a standardized tracking system where businesses use Global Trade Item Numbers (GTINs) to identify products and Global Location Numbers (GLNs) to mark physical facilities like farms, processing plants, and warehouses. Users then log Critical Tracking Events (CTEs), such as harvesting, shipping or receiving via web forms, mobile interfaces, or simple SMS prompts as products move through the supply chain.

Adam Daniels, senior director of product management with GS1-US, says the organization saw a need to make a user-friendly interface to move from paper records to digital records.

“How do we make it so you don’t have to be the expert,” Daniels says. “Everyone is winning by having a simplified tool.”

As Rapid Record logs an event, the system captures key data elements (KDEs), including timestamps, batch numbers, quantities and origin and then stores it in a standardized format to help produce businesses store, manage and share traceability data with trading partners and regulatory authorities.

“We just saw a need for upstream folks with FSMA 204 compliance,” says Liz Sertl, Senior director of supply chain visibility, with GS1-US.

Daniels agrees, noting, “At the end of the day, we want to help people.”

Starfish-at-IFPA.png
Johnna Hepner, vice president of business development and partnerships at Starfish, alongside Wiggs Civitillo at the IFPA Global Produce & Floral Show. Civitillo emphasized that while simplified digital tools help small growers move away from paper records, fresh produce supply chains still face critical friction when attempting to connect ERPs and pass FSMA 204 KDEs forward to proactive retail buyers.
(Photo: Christina Herrick)

Bridging the ERP Gap and Meeting Buyer Demands

At Starfish’s booth, Founder and CEO Wiggs Civitillo, says the messaging now for FSMA 204 should be around what companies need to do ahead of compliance and how to do it. He says there’s a concern in the industry that small-to-mid-sized growers may face more challenges to compliance than larger operations with staff devoted to food safety compliance.

Another major talking point is how retailers are seeking traceability compliance now instead of waiting for July 2028. He says retail and foodservice customers are asking for proactive implementation and are less likely to wait.

“Sellers are being hit with traceability now,” Civitillo says, noting growers are facing fines and rejected shipments without KDEs.

He says that while some might think optimistically that since FSMA 204 implementation got pushed back from January 2026 to July 2028 that it could happen again, he says it’s very unlikely.

“The events this summer renewed a sense of urgency,” he says of the cyclospora outbreak.

He says there’s still opposition for what produce is covered under FSMA 204 with interna systems that all of them to conduct mock recalls. But a pain point still exists in that fresh produce businesses often cannot connect ERPs to share the FSMA 204 CTEs and KDEs forward in the fresh produce supply chain and risk losing customers.

Upcoming Event

Jan. 28–30, 2027  •  Miami Beach, FL

East Coast Produce Expo 2027

Three days of BizMatch+ meetings, trade show and networking at an iconic new location. Plan your trip:

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Sessions, speakers and the first look at the Fresh Trends Consumer Report.

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Fontainebleau Miami Beach. Discounted $409 room rate through Jan. 5.

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