Traceability lot code source: what it is and what to put in the record

The traceability lot code source is the place where a food was assigned its traceability lot code. Under the FDA’s Food Traceability Rule, your receiving and shipping records must carry either that place’s location description or a “source reference” that lets FDA find it. This guide explains both options, who creates the source, and what to check on your records.

What is the traceability lot code source?

The rule’s definitions say the traceability lot code source is “the place where a food was assigned a traceability lot code.” It is a location, not a person or a company name alone.

The traceability lot code itself is a descriptor, often alphanumeric, that uniquely identifies a lot within the records of that source. So, for example, a code such as “L2417” only means something when you know where it was assigned. Two plants could both use “L2417” without conflict, because the pair of code and source keeps them apart.

For the code itself, see our guide to assigning traceability lot codes.

Who creates the lot code source?

The firm that assigns the code. According to FDA’s lot code page, a firm assigns a code when it:

• initially packs a raw agricultural commodity (other than a food from a fishing vessel),
• performs the first land-based receiving of a food from a fishing vessel, or
• transforms a food.

FDA also says firms must not establish a new lot code for other activities, such as shipping. Once assigned, the code must stay the same as the food moves through the supply chain, and it can change only if the food is transformed.

A firm that receives food from a person the rule does not apply to must assign a code if none exists, unless it is a retail food establishment or restaurant (21 CFR 1.1345). When you assign it, your site becomes the source for that lot.

What must the record say?

The same item appears in the receiving and shipping lists. Under 21 CFR 1.1345, receiving records for each lot include the lot code, quantity and unit, product description, the immediate previous source, where it was received, the date received, and “the location description for the traceability lot code source, or the traceability lot code source reference.” Section 1.1340 lists the same element for shipping. Transformation records (21 CFR 1.1350) require the location description for where you transformed the food, which is the source of the new lot.

1. 1Source assigns the lot code
2. 2Shipper sends the code and source
3. 3Receiver records both
4. 4Receiver ships on with the same code

Illustrative flow for a food that is not transformed along the way.

The rule defines a location description as key contact information for the location where a food is handled: the business name, phone number and physical address (or geographic coordinates). Domestic locations add city, state and zip code. Foreign locations need comparable information, including the country.

What is a source reference, and when would I use one?

The rule calls it “an alternative method for providing FDA with access to the location description” for the lot code source. The definition gives two examples:

1. The FDA Food Facility Registration Number for the source.
2. A web address that gives FDA the location description.

One reason to use a reference is confidentiality. The Federal Register preamble notes that a shipper can use a reference to protect confidential business information instead of directly identifying the source’s location.

FDA’s page says the web address may use reasonable security measures, such as only being open to a government email address, but FDA must have access at no cost and without delay. A link that needs a paid login or a callback would likely fail that test.

How do I choose between the two?

Think about who reads the record and how fast.

• Location description: simplest if you are the source. Your name, phone and address already sit on your own labels and invoices.
• Registration number: compact, and works when the source is a registered facility. Confirm the number is correct before you rely on it.
• Web address: useful when many lots share a few sources, since one page can serve every record. Someone must keep the page current, and it must stay reachable.

Whatever you pick, put the choice in your traceability plan, and make the field the same on every record. The electronic sortable spreadsheet is far easier to build when the column holds one kind of value.

What mistakes should I watch for?

• Using the shipper as the source. A distributor that ships a lot did not assign its code. The source is where the code was assigned, upstream.
• Leaving the field blank. The rule lists it as a required element for receiving and shipping records.
• Mixing formats. A phone number in one row and a web address in the next makes sorting hard.
• Letting a web address go dead. FDA needs access without delay.
• Creating a new code at shipping. FDA says not to.

A quick test is a mock recall: pick one received lot and see whether you can name its source in minutes.

On timing, FDA proposed to extend the compliance date for the rule to July 20, 2028, and the page says Congress directed FDA not to enforce the rule before that date. Retailers may ask sooner. See why retailers want your data early.

Where Lotcrumb fits

Lotcrumb is being built to read the lot code and source details on the invoices, bills of lading and labels you already handle, and to keep them in one consistent field for your records. Join the waitlist.

This guide is general information, not legal or regulatory advice. Rules and FDA’s positions can change, so confirm the current requirements on FDA’s website or with a food safety professional.