LotcrumbJoin the waitlist
All guides

Is your food on the FSMA Food Traceability List? A category-by-category check

, 7 minute read

The FDA Food Traceability Rule does not cover all food. It covers foods on the Food Traceability List (FTL), plus foods that contain a listed food as an ingredient in the same form. If your product is not on the list and does not contain a listed food in its listed form, the rule’s recordkeeping generally does not apply to it.

The list is short but full of fine print: “fresh” versus frozen, “soft” versus hard cheese, finfish by species group. This guide walks through it so you can check each product you make, pack or sell.

Where the list lives

FDA publishes the list on its Food Traceability List page. That page is the source of truth, and the footnotes matter. Check the “content current as of” date at the bottom before you rely on any summary, including this one.

FDA says it intends to update the list approximately every five years, subject to resources. If it adds a food, the addition takes effect two years after the Federal Register notice. Deletions take effect immediately (21 CFR 1.1465).

The original compliance date was January 20, 2026. FDA has proposed moving it to July 20, 2028, but had not finalized that change at the time of writing. Separately, Congress’s FY2026 appropriations law directed FDA not to enforce the rule before July 20, 2028, and FDA says it intends to comply. Check FDA’s Food Traceability Rule page for the current date.

The list, category by category

Dairy, eggs and nut butters

  • Cheeses other than hard cheeses. The list has three entries: pasteurized-milk fresh soft or unripened cheese (cottage, chevre, cream cheese, mascarpone, ricotta, queso fresco), pasteurized-milk soft ripened or semi-soft cheese (brie, camembert, feta, mozzarella, taleggio, blue, brick, fontina, monterey jack, muenster), and cheese made from unpasteurized milk, other than hard cheese. The raw-milk entry covers all raw-milk cheeses except hard cheeses. “Hard cheese” means the cheeses defined in 21 CFR 133.150, colby (133.118) and caciocavallo siciliano (133.111), such as cheddar, romano and parmesan. Cheeses that are frozen or previously frozen, shelf stable at ambient temperature, or aseptically processed and packaged are not on the list.
  • Cottage cheese carve-out. In February 2026 FDA exempted cottage cheese that is Grade “A” and on the Interstate Milk Shippers List. Cottage cheese that is not on that list is still covered.
  • Shell eggs. The egg of the domesticated chicken. The entry also includes fresh or frozen products that contain raw, unpasteurized eggs as ingredients.
  • Nut butters. All tree nut and peanut butters, whether shelf stable, refrigerated or frozen. Soy and seed butters are not included. Raw or roasted nuts themselves are not on the list, according to FDA’s FAQ.

Fresh produce

  • Cucumbers, peppers and tomatoes, all varieties.
  • Herbs, such as parsley, cilantro and basil.
  • Leafy greens, such as lettuce, spinach, kale, arugula and chard. Whole head cabbages are not included.
  • Melons, such as cantaloupe, honeydew and watermelon.
  • Sprouts, including bean, alfalfa, broccoli, clover and radish sprouts.
  • Tropical tree fruits, such as mango, papaya, guava, lychee and starfruit. Bananas, pineapple, citrus and avocado are not included.
  • Fresh-cut leafy greens, fresh-cut fruits and fresh-cut vegetables other than leafy greens.

“Fresh” and “fresh-cut” do not include previously frozen forms. Produce on the “rarely consumed raw” list in FDA’s produce safety rule is exempt (21 CFR 1.1305(e)). FDA names dill, collards and figs as examples within the categories above.

Seafood

  • Finfish, fresh, frozen or previously frozen, in three groups: histamine-producing species (tuna, mahi mahi, mackerel, swordfish), species that may carry ciguatoxin (grouper, barracuda, snapper), and other species (cod, salmon, tilapia, trout). Catfish is not included.
  • Smoked finfish, cold or hot smoked, refrigerated, frozen or previously frozen.
  • Crustaceans, such as shrimp, crab, lobster and crayfish.
  • Molluscan shellfish, bivalves, such as oysters, clams and mussels. Scallop adductor muscle is not included. Raw bivalves covered by the National Shellfish Sanitation Program and related requirements are exempt under 21 CFR 1.1305(f).

Ready-to-eat foods

  • Refrigerated ready-to-eat deli salads, such as egg salad, potato salad, pasta salad and seafood salad. Meat salads are not included.

How to check one product

  1. Find the category. Match the product to an entry on FDA’s list, not to a general idea of “high-risk food.”
  2. Check the form. Frozen or dried versions of fresh produce are off the list. FDA’s FAQ gives frozen spinach and dried peppers as examples. Frozen and previously frozen cheeses are off too. For seafood, deli salads and nut butters, frozen and previously frozen versions stay on.
  3. Check the ingredients. See the next section.
  4. Check for an exemption. Size, sales channel and processing can take a listed food out. Our exemptions guide covers the common ones.
  5. Write the answer down. Your traceability plan must describe how you identify listed foods. A product list with the category, the reason and the date of your decision is a simple way to do that.

The ingredient rule

The rule covers a food that contains a listed food, if the listed food stays in the same form it has on the list. FDA’s examples:

  • Covered: a bagged salad mix with fresh lettuce, a smoothie with fresh cantaloupe, a sandwich with fresh tomato slices, and a sandwich cracker filled with peanut butter that gets no kill step.
  • Not covered: a frozen pizza with spinach topping, and trail mix with dried papaya.

Foods that are not on the list do not need records just because they go into a listed food. In FDA’s deli salad example, the maker keeps records for the incoming tomatoes and cucumbers, but not for the olives.

Kill steps

A kill step is lethality processing that significantly minimizes pathogens in a food. If you apply one to a listed food, you are partly exempt. You still keep receiving records for the food and a record that you applied the kill step. Anyone who receives the food after the kill step is exempt (21 CFR 1.1305(d)). If a later business other than a retailer, restaurant or consumer will apply the kill step, a written agreement with your customer saying the kill step will be applied can exempt the food. FDA’s draft guidance describes this for supply chains that know in advance the food will be treated.

So a soup made from fresh greens is generally outside the rule, but the cook keeps receiving records for the greens and a record of the cooking step. “We cook it” is not a blanket exemption. Check the exact conditions.

A quick worksheet

For each product, note:

  • FTL category, or “none”
  • Form: fresh, fresh-cut, frozen, smoked, dried
  • Listed ingredients and whether they stay in listed form
  • Kill step applied, by you or later, and whether you have a written agreement
  • Any exemption you rely on, and why

Where Lotcrumb fits

Lotcrumb is being built for small producers, packers and distributors. The plan is to let you tag each product with its list category and exemption status, then keep the right records for each one in a single place. Join the waitlist for early access.

This guide is general information, not regulatory advice. The Food Traceability List and its footnotes change over time, so confirm each product with FDA guidance or a food safety professional.