Updated October 2026
Food recalls are usually issued against a production lot. If the lot code is recorded when your stock arrives and stays with every order, the recall can stay with that one lot. The FSMA Food Traceability rule asks covered businesses for the same records.
Being ready for a food recall means knowing where each lot went. We record the traceability lot code as your stock is received and keep it with every order, so an affected lot can be pulled on its own instead of your whole catalog. The FSMA Food Traceability rule asks covered parties to keep the lot code, quantity, location and date at receiving and shipping. How your products and role fit the rule is something to talk through with our team.
By The Fulfillment.com team
When something goes wrong with a food product, it rarely goes wrong with every case of it. Contamination, a mislabeled allergen or a packaging fault usually traces back to one production run, made on the same line on the same day. That run is the lot, and recalls are usually written against it. How much a recall costs you then turns on one question. Can you say which orders, customers and storage locations that lot reached?
If you can't, you pull everything, because the other choice is to keep shipping product that might be affected. Pulling the whole line throws away good stock. It stops shipments of lots that were never named. And a problem that started with one batch becomes one your customers associate with the brand. Recording the lot code when stock arrives, and keeping it with each order, gives you the answer before you need it.
The lot record is built as stock moves through the warehouse. It would be hard to piece together afterwards. These are the four places it gets written.
When a shipment of your product reaches our dock, our receiving team records the traceability lot code for each lot and ties it to that stock. The quantity, the shelf it goes to and the date are recorded with it. The rule counts receiving as a Critical Tracking Event. A lot code written down here is one nobody has to guess at later. The same receiving record also sets the order for FEFO (first expired, first out) rotation.
From there the lot code stays with the stock in BestOMS, our order system, with Deposco behind it. Nobody types it in again at each step. Retyping is where lot records usually go wrong. When a picker fills an order, the system records which lot the units came from. Nobody has to remember to write it down.
Shipping is a Critical Tracking Event too. As each order leaves, the order record shows which lot it carried and how many units. It also shows where the order went and on what date. The rule asks for both halves. Receiving shows what came in and from which lot, and shipping shows where each lot went. Ask any 3PL to show you both ends of that record for one of your lots.
The lot is tied to each order in the system, so on the day of a recall the link between lot and order is already there. Nobody has to rebuild it from memory under pressure. How long lot records are kept, and in what form they could be produced, is a question for our team at quote time. We record lots this way for every food and beverage brand we work with, so a recall can be pulled one lot at a time.
The rule sets out what covered parties in the food supply chain have to record. Here is what it says, so you can check your own products and role against it.
The FSMA Food Traceability rule (21 CFR Part 1, Subpart S) is the federal rule on lot-level records for foods on the FDA Food Traceability List. At each Critical Tracking Event in the supply chain, receiving and shipping among them, it asks regulated parties to keep these Key Data Elements:
Those records have to be available to the FDA on request, typically within 24 hours.
Compliance was due on January 20, 2026. FDA has proposed moving that to July 20, 2028 (Federal Register 2025-08-07), and has said it does not intend to enforce the rule before then. For covered foods, then, the requirement is coming but not yet enforced. It is sound practice to keep lot records now rather than wait for the deadline. Whether a given product is covered depends on the Food Traceability List and on your role in the supply chain. Check each of your products against the list, and don't assume either way.
People often mix this rule up with two others. The Food Traceability rule covers records, the data that lets a recall be traced. Registration and preventive controls cover the facility: who has to register, and what food safety plan a facility runs. Our guide to the FDA-registered food facility explained deals with those two, and with what to ask a warehouse about them.
Say one lot of your granola is named in a recall. We look up that lot code. Because it was recorded at receiving and carried onto each order, the lot can be matched to the orders it shipped on and the shelves still holding it. The recall starts there, and stock from your other lots doesn't have to be thrown out just in case.
A brand whose warehouse never kept the lot with the order has no way to tell which orders carried the bad lot. It has to pull the whole product line. Good stock gets scrapped, and lots that were never at risk stop shipping. Pulling one lot is faster, cheaper and smaller, because the records were made as the stock came in and went out.
The best-by date is written down at the same moment as the lot code, and FEFO rotation works from it. Good best-by control can potentially mean fewer cases written off as expired. A clean lot record helps keep a contamination problem contained. Our guide to FEFO vs FIFO for food & beverage covers rotation. Our lot, expiry, and FEFO control service is where we run both.
The lot code we track is the one already printed on your product when it arrives. We don't make or pack the food, so we never assign production lots of our own.
It is the code that ties a unit of food back to the production run it came from. A recall is usually issued against a run. Contamination, a wrong label or an undeclared allergen happens in one batch, and every other case of the same product is usually fine. We record the lot code when your stock arrives and keep it attached through to each order that ships. If a lot is implicated, we can trace it to the orders and storage locations it reached instead of the whole catalog.
Critical Tracking Events (CTEs) are the moments when food changes hands or changes form. Receiving and shipping are two of them. Key Data Elements (KDEs) are what gets written down at each of those moments, starting with the traceability lot code and including the quantity, the location and the date. For foods on the Food Traceability List, the FSMA Food Traceability rule (21 CFR Part 1, Subpart S) requires those records to be kept and passed to the next party in the chain. That chain of records is what lets a recall be followed one lot at a time.
It was set for January 20, 2026. FDA has since proposed moving it to July 20, 2028 (Federal Register 2025-08-07), and has said it does not intend to enforce the rule before then. For covered foods, lot-level records are coming but not yet enforced, and it is sound practice to keep them now. Under the rule, the records kept at receiving and shipping have to be ready for the FDA on request, usually within 24 hours. Tell us your products and where you sit in the supply chain when you ask for a quote, and we'll go through how the rule applies to them.
The code is recorded when the lot comes in, and it stays with every order picked from that lot. When a lot is named in a recall, it can be matched to the orders it shipped on and the shelves still holding it. You start from that one lot. Without that record, nobody can say which orders carried the bad lot, so the safe choice is to pull everything.
Under the FSMA Food Traceability rule, covered parties keep the Key Data Elements for receiving and shipping and produce them for the FDA when asked, typically within 24 hours. We track the traceability lot code from the day a lot arrives to each order it ships on. Ask us how long lot records are kept, and in what form we could produce them, when you request a quote.
Registration is a question about the facility rather than its lot records. Our guide to FDA-registered food facilities covers it, along with FSMA preventive controls. To check either with a warehouse, ask directly: request the registration number, and ask how its preventive-controls practices are documented. Put both to our team when you request a quote, and to any other partner you are weighing.