Mango industry must comply with FDA’s Final Traceability Rule by July 2028

All companies handling mangoes destined for US consumption must comply with the FDA’s Final Traceability Rule by July 20, 2028, regardless of company size, the National Mango Board (NMB) has alerted in a recent seminar. This includes growers, packers, processors, and importers, regardless of company size.

During the webinar "The ABCs of the Food Traceability Final Rule", held on September 24, presenter and food safety specialist Sergio Nieto Montenegro outlined the major implications of the new requirements, which are part of the Food Safety Modernization Act (FSMA). The regulation mandates detailed recordkeeping and traceability across the entire supply chain for mangoes, which are listed on the FDA’s Food Traceability List (FTL).

The rule requires all stakeholders in the supply chain—both US-based and international—to maintain and provide records of Critical Tracking Events (CTEs) and Key Data Elements (KDEs) for mangoes consumed in the United States. Additionally, the rule mandates assigning a Traceability Lot Code (TLC).

The FDA defines CTEs as points in the supply chain where product traceability becomes essential. These include harvesting, initial packing, shipping, receiving, and product processing. Each of these events requires the collection of KDEs, which include the origin and destination of the product, product description, lot identification, date of activity, and reference documents.

“The rule states that only during initial packing or during the processing of your food, you will need to assign a TLC or traceability lot code,” said the presenter. “And that TLC will be associated with the produce throughout the whole supply chain.”

Traceability starts in the field

For harvesters, KDEs include product description (e.g., Ataulfo or Tommy Atkins mangoes), quantity harvested, detailed location of the orchard, date of harvest, receiving facility (such as a packinghouse), and transport documents like bills of lading.

The same structured approach applies to initial packing. Required KDEs include product and orchard descriptions, date of reception, packed quantity, TLC, destination, facility address, and packing date.

If the product is shipped, additional KDEs include the TLC, shipping and receiving locations, date of shipment, and source of the TLC.

“At shipping, I’ll have my traceability lot code, quantity of product, description of the product, and the description of the location that will receive the product,” Nieto Montenegro explained.

Rather than reinventing systems, the webinar emphasized adapting existing practices.

“What I would recommend to you at the onset of this process is to see what you have already, and after that, see what’s missing in your system, and if something is missing, add to it so you don’t go into any redundancy,” Nieto Montenegro said.

The FDA allows flexibility in how records are maintained. Paper systems are allowed, but electronic, sortable spreadsheets such as Excel or Numbers are encouraged — particularly because in a food safety event, the FDA may request records in that format within 24 hours.

“The rule requires you to include a description of the procedures you use to maintain the records required for compliance with the traceability standard, including the format of set records and the location where they will be stored,” Nieto Montenegro added.

Each operation must also designate a contact person and include a map of farm locations with field names and GPS coordinates as part of their traceability plan.

One compliance date for all

Unlike other FSMA rules, the Final Traceability Rule does not stagger compliance deadlines based on company size. All entities must meet the same July 20, 2028, deadline.

“It will be a single date for everyone, regardless of the size of the company,” Nieto Montenegro said.

The NMB is actively offering resources to help companies prepare.

“At the National Mango Board, we have plenty of tools at your service to help you create a plan in compliance with this rule,” he said.

The primary goal of the traceability rule is to enable rapid identification and recall of contaminated food during a foodborne illness outbreak.

“If I have a really solid traceability system, I know exactly the product that caused the problem, I can recall it and therefore protect public health,” the speaker added.

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