FSMA 204 for nut butter makers: what is covered and what to record
Yes, nut butters are on the FDA Food Traceability List, so a company that makes, packs or ships them must keep lot-level records under FSMA 204 unless an exemption applies. The nuts themselves are not on the list. FDA’s Food Traceability List says it “includes all types of tree nut and peanut butters” and does not include soy or seed butters.
This guide covers what counts as a nut butter, who is not covered, how a roasting-and-grinding line creates a lot, and what to write down.
Which nut butters are on the Food Traceability List?
The FDA list covers all forms of nut butters, including shelf-stable, refrigerated, frozen and previously frozen products. Its examples include almond, cashew, chestnut, coconut, hazelnut, peanut, pistachio and walnut butters.
FDA’s Food Traceability Rule FAQs add more detail:
- No legal definition. FDA regulations do not define “nut butter” (item TFTL.14).
- Peanut paste is covered. It falls within the nut butter commodity (TFTL.15).
- Frozen is covered. Frozen nut butters, and multi-ingredient products that contain them, are on the list (TFTL.17).
- Soy and seed butters are not. The list says so directly.
Are raw and roasted nuts covered?
No. FDA’s FAQ (item TFTL.19) says nuts, raw or roasted, are not on the list. Nut roasters are not covered either, unless they also make nut butter. In that case they keep records for the nut butter only.
That matters for a small shop. If you only buy, roast and sell whole nuts, this rule does not reach those products. The moment you grind a batch into butter, that product is on the list.
What about foods that contain nut butter?
FDA’s FAQ treats the ingredient and the finished food differently:
| Situation | FDA’s answer |
|---|---|
| A food contains peanut butter as an ingredient | Covered, even if the label does not name peanut butter (TFTL.18) |
| Nut butter is added to give a nut flavor | The finished product is covered (TFTL.16) |
| Walnut or almond extract is used for flavor | Not covered, because flavorings are not on the list (TFTL.16) |
| A kill step is applied to the multi-ingredient product | May provide an exemption (TFTL.18) |
If you make cookies, bars, spreads or confections with nut butter, read the exemptions guide before you assume you are in or out.
When does grinding nuts create a traceability lot?
This is the question most nut butter makers get wrong. FDA’s FAQ (item TT.3) answers it for a facility that roasts peanuts, makes peanut butter and uses it in a confection:
- One continuous process. If the nut butter is made as part of a single operation and quickly becomes a finished confection at the same location, FDA treats it as one transformation event. Only records for the confection are required, because the nuts are not on the list and the nut butter is not treated as an incoming ingredient.
- A standalone product. If the nut butter is packed or stored before use, it is a separate manufacturing event. Each event needs its own traceability lot code and its own transformation records.
- 1Roast and grind nuts
- 2Packed or stored first?
- 3Yes: new lot code
- 4Record the transformation
- 5No: finished food only
Based on FDA FAQ item TT.3. If the butter flows straight into a finished food, only the finished food needs records. Check your own line with FDA or a food safety professional.
A jar of almond butter sold on a shelf is the standalone case. So is a batch of peanut butter you pack into tubs and hold for a week before using it in bars.
What records does a nut butter maker keep?
When you transform food into a new traceability lot, 21 CFR 1.1350 requires records linked to that new lot. For input foods that are on the list, you record:
- The traceability lot code of each input
- A product description for each input
- The quantity and unit of measure used from each lot
For the food you produce, you record:
- The new traceability lot code
- Where the transformation happened, including the lot code source
- The date the transformation was completed
- A product description
- The quantity and unit of measure
- The reference document type and number for the transformation event
Since nuts are not on the list, a plain nut butter made from raw or roasted nuts has no listed input to trace. Your output records still apply. If you blend in another food that is on the list, that input needs its lot code too. Our transformation records guide goes through what counts, and the lot code guide covers how to build clean codes.
What happens after the jar leaves your door?
Once you ship a lot, the rest of the chain needs your lot code. A retailer or distributor that receives your nut butter is generally covered by the same rule, though some are exempt in part. Our guides for distributors and warehouses and for restaurants and retailers show what they keep and what they will ask you for.
If FDA requests records, the 24-hour sortable spreadsheet guide explains the format.
When do I have to comply?
FDA’s rule page says the original compliance date was January 20, 2026. It says FDA proposed to extend the date by 30 months to July 20, 2028, and that Congress directed FDA not to enforce the rule before that date. Retail buyers may ask for your data earlier. Our compliance date post tracks where this stands.
Where Lotcrumb fits
Lotcrumb is being built to read the roasting logs, supplier invoices and pack sheets you already keep, turn them into lot-level records, and produce a sortable spreadsheet when someone asks. Join the waitlist for early access.
This guide is general information, not legal or regulatory advice. Whether a product is covered or exempt depends on your recipe and process, so confirm it with FDA or a food safety professional.