Food safety ยท Farm records guide
Agriculture Traceability: What Farms Must Record and Why
EU law, and Canadian and Australian produce rules, require farms to name who supplied each lot and who bought it, with dates and a lot code. FSMA 204 adds field-level records and a farm map for listed US foods (enforcement not before July 20, 2028), and the EUDR needs plot coordinates for seven commodities from 30 December 2026.

Key takeaways
- Agriculture traceability means one step back and one step forward: the supplier and the buyer of every lot, with dates and a lot code.
- FSMA 204 covers foods on FDA’s Food Traceability List, such as leafy greens, tomatoes, melons, herbs and shell eggs; FDA says it will not enforce the rule before July 20, 2028.
- Covered US growers need harvest records by field, a written traceability plan with a farm map and coordinates, and records kept for 2 years; produce farms averaging $25,000 or less in sales are exempt.
- From 30 December 2026 the EUDR needs plot polygons with six-decimal coordinates for plots over 4 hectares growing commodities such as coffee, cocoa, soy and palm oil.
- FDA estimated FSMA 204 costs about $570 million a year across all firms, against about $780 million a year in health benefits (7% discount rate, 2020 dollars).
In this article
- What agriculture traceability means on a farm
- Agriculture traceability rules by market at a glance
- United States: FSMA 204 and the Food Traceability List
- European Union: one step back, one step forward
- EUDR: plot geolocation for seven commodities
- Canada: Safe Food for Canadians Regulations
- Australia: horticulture standards and livestock IDs
- How the US and Canadian produce rules compare
- Paper, software, barcodes or satellite maps: choosing a traceability system
- What agriculture traceability costs
- Barcode, label and software costs
- Record-keeping cost calculator
- How to set up traceability in agriculture: 8 steps
- Common gaps that break the chain
Agriculture traceability is the ability to show where a farm product came from and where it went next. In the EU, and for many produce growers in Canada and Australia, a farm must be able to name who supplied each lot and who received it, with dates and a lot code. In the US, the FDA Food Traceability Rule requires detailed records for listed foods such as leafy greens, tomatoes and melons, and FDA now says it will not enforce the rule before July 20, 2028.
This guide explains what farms must record and why, market by market: the US (FSMA 204), the EU (General Food Law and the deforestation rule), Canada and Australia. It then compares paper, software, GS1 barcodes and satellite plot maps, sets out the costs with dated figures, and gives a step-by-step setup. A calculator lets you compare the yearly cost of paper records with software for your own farm.
This page is a plain-English summary, not legal advice. Rules change and exemptions depend on your crop, sales and buyers, so check the rule text, ask your local regulator or buyer, and get professional advice before you rely on it.
What agriculture traceability means on a farm
Traceability in agriculture and food supply chains rests on one simple idea: every business in the chain knows its own link. It knows the supplier of each input and the buyer of each lot. Regulators call this the “one step back, one step forward” approach. If an outbreak or a residue problem appears, investigators can follow those links back to the farm and field much faster.
There are two layers. External traceability is the link to your suppliers and customers. Internal traceability is the link inside your own farm: which field, harvest date and packing run went into which lot. The European Commission’s guidance on the General Food Law says EU law does not demand internal traceability, but notes that it makes withdrawals more targeted. In practice, buyers and newer rules such as FSMA 204 now expect it.
The core record set is short:
- What: the crop or product, variety and quantity, with the unit (for example 75 bins or 200 pounds).
- Where: the farm and the field, block or growing area, ideally with map coordinates.
- When: harvest, cooling, packing and shipping dates.
- Who: the name and address of the business that received the product, and of each input supplier.
- Which lot: a lot code that links the paperwork to the boxes or bins.
- Proof: the bill of lading, invoice or other reference document and its number.
Input records sit next to these. EU hygiene rules already require farmers to keep records of plant protection products and veterinary medicines, which the Commission guidance says covers that gap in the traceability chain.
Agriculture traceability rules by market at a glance
The table below sums up the main rules a farm selling into the US, EU, Canada or Australia may meet. Each has its own section with the source.
| Market | Main rule | What the farm records | Keep records | Status |
|---|---|---|---|---|
| United States | FDA Food Traceability Rule (FSMA 204) | Key data elements for harvesting, cooling, packing and shipping of listed foods, plus a farm map with coordinates | 2 years | FDA will not enforce before July 20, 2028 |
| European Union | General Food Law, Article 18 | Immediate supplier and immediate customer for every product | Not fixed; guidance suggests 5 years | In force since 1 January 2005 |
| EU (deforestation) | EUDR, Regulation (EU) 2023/1115 | Plot geolocation for cattle, cocoa, coffee, palm oil, rubber, soy and wood | 5 years | Applies from 30 December 2026; small firms 30 June 2027 |
| Canada | Safe Food for Canadians Regulations | Food name, lot code, supplier and customer with dates | 2 years | Fresh produce rules in force since January 2020 |
| Australia | Food Standards Code 4.2.7 to 4.2.9 | From whom berries, leafy vegetables and melons came and to whom they went | Not set in the standard | In force since 12 February 2025 |
| Australia (livestock) | NLIS sheep and goat eID | Electronic tag and database record for each movement | Held in the NLIS database | Animals born from 1 January 2025 |
Chart
How long traceability records must be kept
Years, by rule; the EU General Food Law figure is the Commission’s suggested period for most products, not a legal minimum
United States: FSMA 204 and the Food Traceability List
The FDA rule, titled “Requirements for Additional Traceability Records for Certain Foods”, was published as a final rule in the Federal Register on November 21, 2022. It comes from Section 204 of the Food Safety Modernization Act, so the industry calls it FSMA 204. It applies only to foods on the FDA’s list, and to the farms, packers, processors, distributors and retailers that handle them.
Which foods are covered
The Food Traceability List names these fresh crops: cucumbers, herbs, leafy greens (whole and fresh-cut), melons, peppers, sprouts, tomatoes and tropical tree fruits, plus fresh-cut fruits and vegetables. It also covers shell eggs, nut butters, cheeses other than hard cheeses, finfish, smoked finfish, crustaceans, bivalve shellfish and refrigerated ready-to-eat deli salads. Grain, oilseeds and potatoes are not on the list.
Critical tracking events and key data elements
The rule is built on critical tracking events (CTEs) and the key data elements (KDEs) recorded at each one. The final rule lists seven CTEs: harvesting, cooling before initial packing, initial packing, first land-based receiving of seafood, shipping, receiving and transformation. For a farm that harvests a listed crop, the rule text requires these records for each harvest:
- The location of the next recipient of the food (other than the trucker).
- The commodity and, where relevant, the variety.
- The quantity and unit of measure.
- The location of the farm where it was harvested.
- For produce, the field or growing-area name the grower uses, or a location at least that precise.
- The harvest date.
- The reference document type and number, such as a harvest log or bill of lading.
The harvester must pass most of this, plus its business name and phone number, to the initial packer. The initial packer assigns the traceability lot code, which then travels with the food. Every covered business also needs a written traceability plan. Farms that grow or raise a listed food must keep a farm map in that plan showing the growing area, with geographic coordinates. Records must be kept for 2 years. FDA can ask for them within 24 hours, and in an outbreak or recall it can ask for an electronic sortable spreadsheet.
Which farms are exempt
The final rule fully exempts produce farms whose average yearly produce sales over the previous 3 years were no more than $25,000, adjusted for inflation from 2020, and farms already exempt from the Produce Safety Rule under 21 CFR 112.4(a). Shell egg producers with fewer than 3,000 laying hens are also exempt. Farms with average sales of no more than $250,000 do not have to supply the sortable spreadsheet. Other exemptions cover food a farm sells or donates directly to consumers, produce rarely consumed raw, and some foods that receive a kill step later. FDA offers an online exemption tool; use it with your own sales figures.
The compliance date
The original compliance date was January 20, 2026. In August 2025 FDA published a proposed rule to extend the date by 30 months, to July 20, 2028. FDA’s rule page (current as of October 8, 2026) says Congress then directed it not to enforce the rule before that same date, and that FDA intends to comply. When it proposed the extension, FDA said it did not intend to change the record requirements. Congress also told FDA to meet regulated firms every quarter to find possible flexibilities for lot-level tracking, and FDA has a public meeting on this set for November 6, 2026, so some details may still change. Buyers can set their own, earlier dates in supply contracts, so check with your buyers as well as FDA.
European Union: one step back, one step forward
Article 18 of Regulation (EC) No 178/2002, the General Food Law, has applied since 1 January 2005. It covers every food and feed business, including primary producers that grow crops or raise food animals. Each must be able to identify the businesses that supplied it with food, feed or ingredients, and the businesses it supplied, and must hand this information to the authorities on demand. It does not need to identify final consumers.
The law states the goal, not the method, so paper, spreadsheets and software are all acceptable if they work. Article 18 sets no minimum time to keep records. The Commission’s guidance suggests 5 years for most products, 6 months for highly perishable foods with a use-by date under 3 months, such as fresh fruit and vegetables sold to consumers, and shelf life plus 6 months for best-before foods. Extra rules apply to food of animal origin and to GMOs; see the Commission page on GMO traceability and labelling for one example.
EUDR: plot geolocation for seven commodities
The EU Deforestation Regulation (EUDR) adds a new kind of agriculture traceability: proof of exactly where a commodity was grown. According to the Commission’s EUDR implementation page, from 30 December 2026 products placed on, sold within or exported from the EU must be deforestation-free. It covers cattle, cocoa, coffee, palm oil, rubber, soy and wood, and some products made from them. The Commission’s July 2026 guidance confirms that micro and small companies set up by 31 December 2024 follow from 30 June 2027, except for timber products already under the old EU Timber Regulation.
The key farm-level record is the geolocation of each plot of land. The Commission’s EUDR FAQ (version 5, April 2026) sets out the format:
- Plots larger than 4 hectares (other than cattle): a polygon of latitude and longitude points with six decimal digits around the whole plot.
- Plots under 4 hectares: a polygon or a single point, also with six decimal digits.
- Cattle: a single point for each establishment where the animals were kept.
- Micro and small primary operators: in their simplified declaration, a postal address may replace coordinates if it clearly matches the plots.
- Cut-off date: the land must not have been deforested after 31 December 2020.
Six decimal digits locate a point to about 0.1 m. The FAQ says a mobile phone, a handheld GNSS receiver or a common GIS app can capture the coordinates, and that satellite images, air photos or geotagged field photos can be used to check them. The EUDR places its duties on businesses that place products on the EU market, not directly on farmers outside the EU, but EU importers must collect the plot data from their suppliers. Coordinates are needed even for land in countries rated low risk. Operators must keep the information for 5 years.
โถ Three ways to get a field boundary into a farm mapping app: tap the corners on satellite imagery, drop a circle over a pivot, or upload a boundary file. ยท 2:21
Canada: Safe Food for Canadians Regulations
Canada’s rules apply to growers and harvesters of fresh fruits or vegetables that are exported or sent across provincial or territorial borders. For most fresh produce businesses they came into force on January 15, 2020. The CFIA’s traceability toolkit lists what each record must show:
- The common name of the food, the name and address of the business that produced or packed it, and a lot code or other unique identifier.
- One step back: who supplied the food and the date it was received.
- One step forward: who received the food and the date it was provided.
Records must be clear, kept for 2 years, accessible in Canada and provided to the CFIA on request. Electronic records must come as a single file that opens in standard commercial software. Retailers trace one step back only, since they sell to consumers.
Australia: horticulture standards and livestock IDs
Australia added three primary production standards to the Food Standards Code for berries (4.2.7), leafy vegetables (4.2.8) and melons (4.2.9). Western Australia’s health department confirms they are enforced Australia-wide from 12 February 2025. Each standard requires growers and primary processors to have a system that can identify from whom the produce was received and to whom it was supplied.
The FSANZ guide Safe Horticulture Australia (November 2024) lists best practice: supplier and customer contact details, dates, batch or lot numbers, quantities, and regular mock recalls to test the system. It notes that knowing the growing site for each batch can limit a recall to the affected batches only.
For livestock, the National Livestock Identification System (NLIS) traces animals. The Integrity Systems Company says that sheep and farmed goats born on or after 1 January 2025 must carry an approved electronic tag before they leave their property of birth, and movements must be recorded in the NLIS database. US cattle have their own animal disease traceability rules for interstate movement; see the USDA APHIS traceability page.
How the US and Canadian produce rules compare
Many North American growers ship to both countries. The Produce Traceability Initiative, an industry group, publishes a side-by-side comparison of FSMA 204 and the SFCR (revised November 2025). The main points:
| Data element | FSMA 204 | SFCR |
|---|---|---|
| Lot code by case | Yes | Yes (lot code or unique identifier) |
| Keep records 2 years | Yes | Yes |
| Shipped from and to | Yes | Yes |
| Ship or receive date | Yes | Yes |
| Data within 24 hours | Yes | Yes |
| Quantity shipped | Yes | No |
| Reference document | Yes | Recommended |
| Written plan | Yes | No |
| Harvest and cooling | Yes (initial packer) | No |
| Sortable spreadsheet | Yes | Single file if electronic |
In the PTI table, every SFCR record element marked Yes is also required by FSMA 204, so a record set built for FSMA 204 covers them. The exceptions are labels: the SFCR requires a label on cases and consumer items, and a lot code on consumer prepackaged produce, which FSMA 204 does not.
Paper, software, barcodes or satellite maps: choosing a traceability system
No rule above names a technology. The right system depends on how many lots you ship, who buys them and which rules apply. Here are the five main options, from the simplest.
โถ Farmonaut traceability features for recording farm inputs, pest and infestation data and farmer details. ยท 0:56
1. Paper logs and spreadsheets
Bound harvest logs, bills of lading and a spreadsheet that ties lot codes to fields. Low cash cost, but each record takes staff time, and FDA’s sortable spreadsheet must be built by hand. Best for: small farms with few lots and one or two buyers, or farms exempt from FSMA 204 that still need EU or SFCR one-up, one-down records.
2. Farm management or traceability software
Apps that log harvests, inputs and shipments on a phone and export reports. They cut the minutes per record and can produce the sortable spreadsheet in one step, for a yearly fee. Best for: farms shipping hundreds of lots a year, or with many fields and crews. Our digital agriculture tools comparison covers some of the options.
3. GS1 barcodes and case labels
A GS1 Global Trade Item Number (GTIN) plus a lot code on each case lets packers and buyers scan rather than type. The Produce Traceability Initiative recommends a case label carrying the lot code. Check whether your buyers require GS1-issued numbers. Best for: packers and grower-shippers selling to retail chains.
4. Satellite and GPS plot maps
Field boundaries drawn on satellite imagery or walked with GPS give the farm map with coordinates that FSMA 204 asks for and the plot polygons the EUDR requires. One map, kept up to date, also gives each field a stable name for harvest records. Best for: growers of EUDR commodities such as coffee, cocoa, soy, rubber and palm oil, and FSMA 204 growers who need a farm map.
5. Shared or blockchain ledgers
Some buyers run shared digital ledgers so each partner adds records that others can see but not change. They still depend on correct data entry at the farm. Best for: farms whose buyer already runs such a platform and asks suppliers to join.
What agriculture traceability costs
FDA’s final rule gives the main public estimate of what detailed food traceability costs. At a 7% discount rate over 20 years, it estimated annualized costs of about $570 million a year across all covered businesses (2020 dollars). It put the yearly health benefits at about $780 million, based on an estimated 83% cut in traceback time for four pathogens, plus about $575 million from avoiding overly broad recalls and market withdrawals.
Chart
FDA’s central estimates for the traceability rule
US$ million per year, annualized over 20 years at a 7% discount rate, 2020 dollars, all covered businesses
The range around those central figures is very wide, because FDA was unsure how many firms already keep such records. The low and high estimates differ by more than 30 times for costs. FDA also estimated that reading and understanding the rule takes about 16.8 hours per firm on average.
Chart
FDA’s low and high estimates for FSMA 204
US$ million per year, annualized over 20 years at a 7% discount rate, 2020 dollars
Barcode, label and software costs
For a single farm, the main costs are staff time per record, any software subscription, case labels and barcode numbers. The GS1 US price list (list prices shown in October 2026) charges $30 for a single GTIN with no renewal, and $250 up front plus $50 a year for a company prefix with 10 numbers. A prefix for 100 numbers costs $750 plus $150 a year. GS1 offices in Canada, the EU, the UK and Australia set their own fees.
Chart
GS1 US barcode fees by number of products
US$ list prices for a GS1 Company Prefix by capacity (number of GTINs), as shown in October 2026
Record-keeping cost calculator
Use the calculator below to compare the yearly cost of paper records with software for your farm. Enter your own lots, minutes per record, wage and software quote. Label and barcode costs are shown on their own, because they apply with either method.
Try the numbers for your own farm below.
Calculator
Paper or software: what do traceability records cost you a year?
Enter your own lots, record times, wage and software quote.
- Paper: staff time per year: $1,000
- Software: staff time plus fee: $1,033
- Labels and barcode numbers (either way): $350
- Lots per year where software breaks even: 525 lots
- Total cost per lot, paper: 2.70 $ per lot
- Total cost per lot, software: 2.77 $ per lot
Example values only, not a benchmark or a forecast; every number is your input. The defaults were chosen so paper and software come out close, to show how the comparison works. ‘Lots per year’ means each harvest, packing or shipping record you write. The $50 barcode fee default is the GS1 US annual renewal for a 10-number company prefix (GS1 US price list, October 2026); the label cost and software fee are examples. If software does not save time per record, the break-even line is not meaningful.
How to set up traceability in agriculture: 8 steps
These steps follow the record lists in the FDA, CFIA, EU and FSANZ sources above. Start with the strictest rule that applies to you; it usually covers the others.
- Check which rules apply. List your crops, buyers and export markets. Check the FDA Food Traceability List and exemption tool, the SFCR if you ship across Canadian provinces, the EUDR if you grow one of its seven commodities for the EU, and your state or territory food agency in Australia.
- Map and name every field. Draw each field or block on a map, give it a fixed name, and store its boundary coordinates. EUDR plots over 4 hectares need full polygons.
- Choose a lot code rule. For example field code plus harvest date plus crew or packing line. Keep it short and print it on every bin, case or delivery note.
- Set up the record forms. One line per harvest or shipment: commodity, variety, quantity and unit, field, date, recipient, lot code and reference document number.
- Record inputs too. Seed lots, fertilizer and plant protection products, with dates and fields. Follow the label and local rules for every product.
- Write the traceability plan. Who records what, where records are kept, how lot codes are made, and a contact person. FSMA 204 requires this plan in writing.
- Train staff and keep the records. Keep them for at least 2 years (FSMA 204 and SFCR) or 5 years (EUDR and EU guidance for most foods).
- Run a mock recall. Pick a lot and time how long it takes to list its fields, inputs and buyers. FDA can ask for records within 24 hours, so aim well under that.
โถ A full walkthrough of adding a field: search an address or coordinates, draw the boundary, and fill in the field details. ยท 3:50
Common gaps that break the chain
- Field names that change. If staff call the same block “north 40” and “field 7”, records cannot be matched. Fix the names on one map.
- Lot codes that do not reach the case. A lot code in a notebook but not on the box cannot be traced.
- Mixed lots. Combining harvests from several fields into one bin without noting each field spreads any recall to all of them. The EUDR FAQ makes the same point for bulk commodities.
- Records nobody can find in a day. A mock recall shows this before a regulator does.
- Plot data that is too rough. A single point for a large plot does not meet the EUDR polygon rule.
Related pages on our site: sustainable farming techniques, traditional agriculture steps, technology in agriculture, soil health management, the mobile app, the Farmonaut API and the API developer docs.
FAQ
What is traceability in agriculture?
It is the ability to follow a farm product one step back to its suppliers and one step forward to its buyers, with lot codes and dates. Newer rules such as FSMA 204 and the EUDR also link each lot to the field or plot where it grew.
When must farms comply with FSMA 204?
The original date was January 20, 2026. FDA proposed moving it to July 20, 2028, and its rule page says Congress directed FDA not to enforce the rule before that date. Buyers may ask for the data sooner.
Does the EUDR apply to farms in the US, Canada or Australia?
Not directly, unless the farm itself places products on the EU market. But EU importers of cattle, cocoa, coffee, palm oil, rubber, soy and wood products must collect plot geolocation from their suppliers, so exporters of these goods will be asked for it, even from low-risk countries.
How long should farm traceability records be kept?
Two years under FSMA 204 and Canada’s SFCR, and 5 years under the EUDR. EU Article 18 sets no fixed period; the Commission’s guidance suggests 5 years for most products and 6 months for highly perishable foods sold to consumers.
Do I need software for traceability?
No rule requires it. Paper and spreadsheets are allowed if you can produce the records in time. Software saves time when you ship many lots, and makes FDA’s sortable spreadsheet easier to produce.
Farmonaut agriculture API
Add field boundaries and satellite crop data to your platform
Agtech and traceability teams can pull field-level satellite crop health and weather data into their own apps through the Farmonaut agriculture API (farmonaut.com/farmonaut-agriculture-api).

Sources
- FDA, FSMA Final Rule on Requirements for Additional Traceability Records for Certain Foods (rule page, current as of 8 October 2026): fda.gov
- FDA, Food Traceability List (current as of 24 July 2026): fda.gov
- FDA, Requirements for Additional Traceability Records for Certain Foods, final rule, Federal Register 87 FR 70910 (21 November 2022): govinfo.gov
- FDA, Requirements for Additional Traceability Records for Certain Foods: Compliance Date Extension, proposed rule, Federal Register (7 August 2025): govinfo.gov
- European Commission, Guidance on the implementation of articles 11, 12, 14, 17, 18, 19 and 20 of Regulation (EC) No 178/2002 on general food law (26 January 2010): food.ec.europa.eu
- European Commission, GMO traceability and labelling: food.ec.europa.eu
- European Commission Green Forum, Implementing the EU Deforestation Regulation (EUDR): green-forum.ec.europa.eu
- European Commission, Frequently Asked Questions: Implementation of the EU Deforestation Regulation, version 5 (April 2026): environment.ec.europa.eu
- European Commission, Guidance Document for Regulation (EU) 2023/1115 on Deforestation-Free Products, C(2026) 4972 (13 July 2026): green-forum.ec.europa.eu
- Canadian Food Inspection Agency, Traceability: toolkit for food businesses (Safe Food for Canadians Regulations): inspection.canada.ca
- Canadian Food Inspection Agency, New federal food safety requirements now in force for fresh fruits or vegetables (15 January 2020): canada.ca
- Government of Western Australia, Department of Health, Berries, leafy vegetables and melons standards: health.wa.gov.au
- Food Standards Australia New Zealand, Safe Horticulture Australia, 1st edition (November 2024): foodstandards.gov.au
- Integrity Systems Company, What is sheep and goat eID (NLIS): integritysystems.com.au
- USDA APHIS, Animal disease traceability: aphis.usda.gov
- Produce Traceability Initiative, PTI comparison of FSMA 204 and SFCR required data elements (revised November 2025): producetraceability.org
- GS1 US, Get UPC barcodes: price table (list prices, viewed October 2026): gs1us.org
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