Keeping up with changing regulations can be a full-time job for a farming business. If you are a family farm growing fresh produce, we cut to the must-know details in your journey to prepare for the latest changes from the FDA.
FSMA 204 Explained
The Food Safety Modernization Act (FSMA) was designed to improve food safety practices in the USA. Recently approved Section 204, the FDA outlines additional traceability requirements for certain foods. These new requirements will come into effect on January 20th, 2026.
For family farms growing fresh produce, that means you only have one season (2025) to adapt and validate your reporting processes to be ready for the new traceability reporting requirements.
To help prepare you for 2026 we have a 3 part series on FSMA 204 for fresh produce, family farms.
- October 18th: FSMA 204 Explained
- November 14th: FSMA 204 Preparation Checklist
- December 16th: FSMA 204 Tools & Resources
Want to stay up to date on the latest FSMA 204 news for Fresh Produce, Family Farms?
Join our email Newsletter and get the latest news direct to your inbox.
Who is in Scope:
FSMA 204 requires traceability records for farms (and processors, packers, holders) who produce any food item on the Food Traceability List. Keep in mind that FSMA regulations only apply to commercially grown, packed, and processed food or feed. Home gardeners or home food preservers are not covered under the law.
For fresh fruit & vegetable growers, the following crop categories are in scope:
- Cucumbers
- Tomatoes
- Herbs
- Lettuce and other leafy vegetables; most notably arugula, baby leaf, butter lettuce, chard, chicory, endive, escarole, green leaf, iceberg lettuce, kale, red leaf, pak choi/bok choi, Romaine, sorrel, spinach, and watercress
- Melons; most notably cantaloupe, honeydew, muskmelon, and watermelon
- Peppers
- Sprouts; most notably alfalfa sprouts, allium sprouts, bean sprouts, broccoli sprouts, clover sprouts, radish sprouts, alfalfa & radish sprouts
- Tropical tree fruits; most notably mango, papaya, mamey, guava, lychee, jackfruit, and starfruit
Exemptions
There are several exemptions, even if you are growing the crops listed above.
- Small farms with sales under < $25,000 annual average during the previous three years
- Farms selling food directly to consumers
- Certain food produced and packaged on a farm
- Food that receives certain types of processing
If you have any doubt whether or not your farming business is in scope, there is an online tool available to support you in determining who is exempt from FSMA 204 Traceability Reporting.
What to Expect
So you’ve determined that you’re in scope for FSMA 204.
What does that really mean?
In short, you have an obligation to maintain data records relating to your production. The most common action here from growers will be to document key data points with respect to your harvest activities. Note the new terminology here. Harvest is considered a Critical Tracking Event (CTE) and you need to keep particular Key Data Elements (KDE) when you complete this event (harvest).
So what data points are necessary to document for Harvest? We’ve summarized the main points below.
Key Data Elements (KDEs) to maintain on farm for the Harvest CTE:
“The setup is super easy/foolproof and was done in just a few minutes”
Who is benefiting from the harvest labels most in his operation?
- Operating Company Name
- Commodity Description
- Crop Variety
- Field Name / Harvest Area
- Harvest Date
- Harvest Quantity & Unit of Measure
- Complete Farm Address: Street AddressCity, State, Zip or Postal Code, Country
- Alternatively Farm GPS Coordinates
- Farm Phone Number
- Business Details for the ‘Immediate Subsequent Recipient’
– Including business Name, complete business address and phone number
If you also have operations on farm such as cooling, packing, shipping, and receiving activities; then you should follow the links below for the respective KDE for each of the other CTEs relevant to your business. You can find the complete details online at the FDA website under Electronic Sortable Spreadsheet.
Farms must ensure these records are clear and accessible within a specific timeframe.
Paper-based systems are permitted but can be time consuming and prone to error. Some family farms will want to consider new software for tracking harvest records easily and minimize the administrative burden of paper-based records.
Terms to Know:
Farms will need to track certain “Key Data Elements” (KDEs) across “Critical Tracking Events” (CTEs).
- Harvesting
- Cooling
- Initial Packing
- First Land-based Receiving
- Shipping
- Receiving
- Transforming
- Farm Name
- Field Location
- Harvest Quantity
- Farm Address or GPS Coordinates
- Business Details for the ‘Immediate Subsequent Recipient’
Conclusion
For family farms, FSMA 204 means a greater focus on documentation and possibly a transition from traditional, informal record-keeping methods. While complying with FSMA 204 may require upfront effort, traceability can be a selling point, especially with larger retail chains or grocery stores that may require verified traceability from suppliers. With the right systems in place, it can be a manageable process that helps ensure food safety and bolster the farm’s credibility.