What to do when a supplier does not send a traceability lot code
If a supplier ships you a food on the FDA Food Traceability List without a traceability lot code, the rule puts the duty to send it on the supplier, but it also puts the duty to record it on you. Do not make up a code and do not change theirs. Ask the supplier for the code in writing, keep the request, and record whatever you do receive. If you only receive and pass the food on, the one case where you assign a code is food from a supplier the rule does not cover.
This guide explains who owes what, how a lot code can be sent, and a simple way to chase missing data.
Who must send the lot code?
The shipper. Under 21 CFR 1.1340, a business that ships a listed food must give the next recipient the lot code, the quantity and unit of measure, the product description, the ship-from and ship-to locations, the shipping date, and the lot code source (or a reference to it). The rule says this may be done “in electronic, paper, or other written form.”
The reference document type and number is a record you keep. It is not on the list that must be sent. Shipments of a raw agricultural commodity (other than food from a fishing vessel) before it is initially packed are outside this section.
What must I record when I receive it?
21 CFR 1.1345 says that for each traceability lot you receive, you keep records linked to the lot. They include:
- The traceability lot code
- The quantity and unit of measure
- The product description
- The location of the immediate previous source (not a transporter)
- The location where you received the food
- The date you received it
- The location of the lot code source, or the source reference
- The reference document type and number
If the code is missing, item 1 is missing, and so your record is incomplete. That is why a gap at the dock becomes your problem, even though the shipper owes you the data.
Can I assign a code myself?
Only in a narrow case. FDA’s traceability rule FAQs (item TTLC.1) say a code must be assigned when a business initially packs a raw agricultural commodity, does first land-based receiving of food from a fishing vessel, or transforms a food. The same item says a person may not change a code if they are not performing one of those events: “a distributor should not change the TLC provided to them.”
The exception is in 1.1345(b). When you receive a listed food from a person the rule does not apply to, you must assign a lot code “if one has not already been assigned.” Retail food establishments and restaurants are excused from that step. Whether a supplier is outside the rule depends on the exemptions in 21 CFR 1.1305, so check with FDA or a food safety professional before you rely on it. Our exemptions guide lists the common ones.
| Situation | Who assigns or keeps the code |
|---|---|
| Supplier is covered and already assigned a code | You record their code. Do not change it. |
| Supplier is covered but sent no code | They still owe it. Ask, and record what arrives. |
| Supplier is not covered by the rule | You assign a code when you receive (retail and restaurants excepted). |
How can the code reach me?
It does not have to be printed on the box. FDA’s FAQ (item TTLC.3) says the rule does not require the lot code on food labeling or packaging. It can be sent “via a bill of lading, an advance shipment notice (ASN), in a separate email, or by embedding the information in a quick response (QR) code.” The information must be provided in a way that lets the receiver keep the records the rule requires.
So an email or a bill of lading can satisfy the rule. It also means a missing sticker is not always a missing code. Check the paperwork before you decide the data is absent.
The lot code source can be sent as a source reference instead of a full address. FDA’s FAQ (item TTLC.2) names a food facility registration number or a web address as examples, including a web address in a QR code or a GS1 Digital Link.
- 1Receive listed food
- 2Check label, BOL, ASN and email
- 3Ask the supplier in writing
- 4Record what arrives, with the date
- 5Keep the request on file
Illustrative process, not a required order.
How do I ask a supplier for it?
Keep the request short and specific. A message like this works:
- Name the food and the delivery (PO number, ship date).
- List the items you need: lot code, quantity, ship-from location, lot code source or reference.
- Say how you can take it: email, spreadsheet, EDI or a portal.
- Give a date to reply.
Save the message with your receiving file. The rule does not say how you must chase a missing code, so this is a practice, not a requirement. It still shows you tried, and it speeds up the next delivery.
Put the ask in your purchase terms too. Our guide to assigning traceability lot codes also covers what to do when a supplier does not send a code.
Does any of this apply yet?
FDA’s rule page says FDA proposed extending the compliance date to July 20, 2028, and that Congress directed FDA not to enforce the rule before that date. The original date was January 20, 2026. Buyers can ask for the data earlier, as our retailer guide explains. Starting supplier conversations now gives vendors time to fix their paperwork.
Where Lotcrumb fits
Lotcrumb is being built to read the invoices, bills of lading and labels you already receive, pull out lot codes and the other key data, and flag the lots where a code is missing so you know whom to ask. Join the waitlist for early access.
This guide is general information, not legal or regulatory advice. Whether a supplier is covered or exempt depends on the facts, so confirm it with FDA or a food safety professional.