LotcrumbJoin the waitlist
All guides

FSMA 204 for produce farms: harvest, cooling and packing records

, 5 minute read

If your farm grows a fresh produce item on the Food Traceability List and no exemption applies, the FDA Food Traceability Rule asks you to keep a record each time you harvest it. If you also cool it before packing, you keep a cooling record, and you must send the harvest and cooling details to whoever packs it. FDA’s recordkeeping fact sheet for produce farms (June 2023) lays out these requirements.

This guide covers who is covered, what to record at each step, what to hand to the packer, and what goes in a farm traceability plan.

Is my farm covered by FSMA 204?

FDA’s coverage and exemptions fact sheet for produce farms (June 2023) says the rule “covers farms unless a specific exemption applies.” It lists these produce items on the Food Traceability List:

  • Cucumbers, fresh herbs, fresh leafy greens, melons and peppers
  • Fresh sprouts and tomatoes
  • Fresh tropical tree fruits such as mango, papaya and guava
  • Fresh-cut fruits and fresh-cut vegetables

The fact sheet also lists the main farm exemptions, with the section of 21 CFR 1.1305 for each:

  • Farms not covered by the Produce Safety Rule are exempt for the produce they grow.
  • Small produce farms are exempt when their average annual produce sales, plus the value of produce they pack or hold without sale, over the previous 3 years are no more than $25,000, adjusted for inflation with 2020 as the baseline year.
  • Direct-to-consumer sales are exempt when the farm sells or donates food it produced directly to a consumer.
  • Food produced and packaged on the farm is exempt if the packaging stays in place until the food reaches the consumer and the label carries the farm’s name, address and phone number.
  • Produce receiving a kill step or commercial processing is exempt in specific cases, and for the kill-step case written agreements must be in place.

Each exemption has conditions, and this list is a summary. FDA also publishes an exemptions page for produce farms. Read the rule text or ask FDA or a food safety professional before you decide you are exempt. Our exemptions guide goes deeper.

What do I record at harvest?

The fact sheet says that for each Food Traceability List produce item you harvest, you keep a record with these key data elements:

  1. The location description for the next recipient (other than a transporter)
  2. The commodity and, if applicable, the variety
  3. The quantity and unit of measure
  4. The location description for the farm where it was harvested
  5. The name of the field or other growing area, matching the name you use as the grower, or information at least as precise
  6. The date of harvesting
  7. The reference document type and number

The field name is the one most farms do not already write down per load. The rule text in 21 CFR 1.1325 says it must correspond to the name the grower uses.

What do I record if I cool the produce?

If you cool produce before it is initially packed, you also keep a cooling record. Under 21 CFR 1.1325, it holds:

  1. The location description for the next recipient (other than a transporter)
  2. The commodity and, if applicable, the variety
  3. The quantity and unit of measure
  4. The location description for where you cooled the food
  5. The date of cooling
  6. The location description for the farm where it was harvested
  7. The reference document type and number

What must I send the packer?

Keeping the record is only half of it. The fact sheet says that for each listed item you harvest, you must provide the initial packer with your business name, your phone number, and your harvest key data elements, except the reference document type and number. You can do this in electronic, paper or other written form.

If you cool the produce, you likewise provide the cooling details to the initial packer, again without the reference document type and number.

A paper harvest ticket that travels with each load can carry all of this. Our key data elements guide shows the same fields for every event.

What if my farm also packs the produce?

Then you are the initial packer too, and the rule adds more. For each traceability lot you initially pack, the fact sheet says you keep records that link to that lot. They include the receipt date, the harvest and cooling details, the traceability lot code you assigned, a description and quantity of the packed food, where you packed it, and the date of initial packing.

You must assign the traceability lot code. FDA defines it as “a descriptor, often alphanumeric, used to uniquely identify a traceability lot within the records of the traceability lot code source.” Our lot code guide covers formats. When you ship packed produce, shipping records apply as well, and you must send shipping information to the next recipient.

What goes in a farm traceability plan?

The fact sheet says every covered entity keeps a traceability plan. For a produce farm, it includes:

  • How you keep the required records, including their format and location
  • How you identify foods on the list that you manufacture, process, pack or hold
  • How you assign traceability lot codes, if applicable
  • A point of contact for questions about the plan and records
  • A farm map showing each field or growing area where you grow listed produce, including geographic coordinates. It can be digital or hand drawn.

You must update the plan when practices change and keep the old plan for at least 2 years after an update. Our plan template guide has a layout you can copy. FDA also posts a traceability plan example for farms.

When do these records become mandatory?

Check FDA’s rule page before you plan around a date. It says FDA proposed to extend the compliance date by 30 months to July 20, 2028, and that Congress directed FDA not to enforce the rule before that date. The original date was January 20, 2026. Retail buyers may ask for the data sooner, so it is worth building the habit now.

Where Lotcrumb fits

Lotcrumb is being built to turn the harvest tickets, packing logs and bills of lading you already have into lot-level records, and to produce a sortable spreadsheet when someone asks. Join the waitlist for early access.

This guide is general information, not legal or regulatory advice. Your obligations depend on your crops and operations, so confirm them with FDA or a food safety professional.