Traceability Food Safety Rules: What Restaurants Must Record

Traceability food safety is the record trail that lets a contaminated product be found fast. When an outbreak is traced to romaine lettuce, investigators need to know which farm, which harvest date, which distributor and which restaurants received it. If those records exist, the recall is narrow and quick. If they do not, everyone throws away all their romaine for weeks and people keep getting sick.

For restaurants this used to be a "good practice". It is becoming a requirement. The FDA's Food Traceability Rule, written under section 204 of the Food Safety Modernization Act, requires records for foods on the Food Traceability List, and it reaches restaurants at receiving. The FDA has extended the compliance date to July 20, 2028, which gives kitchens time to build the habit now.

This guide explains traceability in plain terms, what the rule asks of restaurants, and how to fold it into the receiving log you already keep. Sources: the FDA Food Traceability Rule page and the FDA Food Code 2022.

What traceability means: one step back, one step forward

Traceability rests on a simple idea. Each business in the chain records where food came from and where it went. Put those records together and you can trace a product from the restaurant plate back to the farm, or from a contaminated lot forward to every place that received it.

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Restaurants are usually the end of the chain, so most of their obligation is the step back: keep good receiving records and be able to say which lots you had on which days.

The Food Traceability List

The rule covers only foods on the Food Traceability List (FTL). The list includes:

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If a listed food has been changed in a way that kills pathogens, for example canned tomatoes, it usually falls outside the rule.

Key data elements for receiving

When a covered restaurant receives a listed food, it must keep these key data elements (KDEs):

• The traceability lot code for the food.
• The quantity and unit of measure (for example, 6 cases).
• The product description.
• The location description of the immediate previous source (your distributor).
• The location description where the food was received (your restaurant).
• The date you received it.
• The location description of the traceability lot code source, or its reference.
• A reference document type and number, usually the invoice or bill of lading.

In practice, a distributor's invoice that shows the lot codes plus your receiving log with date and temperature covers most of these. The rule asks you to keep records for two years and give FDA an electronic sortable spreadsheet within 24 hours during an outbreak investigation.

Who is exempt

The rule has exemptions for small businesses. A restaurant or retail food establishment with average annual food sales of 250,000 dollars or less over the past three years is exempt from most requirements, and there are partial exemptions for some direct-to-consumer farm sales. Check the FDA exemption tool before assuming you are covered or not.

How the traceability food safety rule reaches restaurants

FSMA's Food Traceability Rule is different. It requires additional records for foods on FDA's Food Traceability List, such as certain fresh produce, shell eggs, finfish and soft cheeses, for anyone who manufactures, processes, packs or holds them, including many retail food establishments and restaurants. The rule has exemptions, including for some small retail food establishments and restaurants, and FDA has published guidance about enforcement for certain smaller ones.

According to FDA's Food Traceability Rule page, the original compliance date was January 20, 2026, and FDA intends not to enforce the rule before July 20, 2028, following a directive from Congress. FDA also lists resources specifically for restaurants. Check FDA's current guidance, because this area is still changing.

For restaurants, the rule mostly concerns receiving records: keeping key information about traceability list foods you receive and linking them to supplier lot codes. Your receiving log is a natural place to start. See the receiving temperature log.

Why receiving is the heart of traceability

In most restaurant hazard analyses, receiving is not a critical control point for cooked items, because cooking later controls the bacteria. It is still a key control step, for three reasons.

First, some hazards cannot be fixed later. Scombrotoxin (histamine) in tuna or mahi-mahi forms when the fish is temperature abused and cooking does not destroy it. Staphylococcus aureus toxin is heat stable too. If the product arrives abused, the damage is done.

Second, some food is never cooked. Salad greens, cut fruit, oysters served raw and deli meats rely on cold temperature from the farm to the plate. Receiving is one of the few times you can check that the supply chain did its part.

Third, a receiving log is evidence. When an inspector or a customer complaint asks where a problem started, a log showing 38°F at delivery points away from the supplier and toward your own storage or handling. A log showing nothing proves nothing.

Many plans for raw oysters and raw fish make receiving a CCP for exactly this reason. See critical control point examples for how to decide.

What to record on a receiving log

A useful receiving log has one row per item checked:

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Some kitchens add a column for the truck temperature or a note on how long the delivery sat before it was checked. Keep the log on a clipboard by the back door or in the receiving area, not in the office, so it actually gets used.

Receiving and supplier approval

The Food Code requires food to come from approved sources. Receiving checks are your evidence that suppliers keep their part of the deal. If one supplier keeps delivering warm product, that is a reason to talk to them and, if needed, change suppliers. Keep a short list of approved suppliers with contact information in your plan.

Questions to ask a new supplier

Before your first order from a new supplier, ask:

• How are refrigerated and frozen products kept during delivery? Is the truck refrigerated, and is it monitored?
• What is the delivery window, and can it avoid your busiest hours?
• What happens when you reject a product? Is there a credit, and how fast?
• For seafood: can they provide shellstock tags and parasite destruction records where required?
• For produce: do they sell cut produce, and how is it kept cold?
• Can they give you a contact for temperature complaints?

Write the answers down. If problems start later, you have a record of what was promised.

When to reject a delivery

Reject when:

• refrigerated TCS food is above 41°F, unless a specific exception applies
• hot food is below 135°F
• frozen food shows signs of thawing and refreezing
• packages are torn, leaking or swollen, or cans are dented on the seam, bulging or rusted
• ready-to-eat items are not properly sealed
• shellstock has no tag
• the food shows pest damage
• the product is not from an approved source, such as home-canned items
• the smell, color or texture is clearly wrong

Rejecting a delivery feels awkward with the driver standing there. It is much less awkward than explaining to an inspector why you accepted warm chicken. Write the reading on the invoice, have the driver initial it if possible, and record it on the log.

How long to keep receiving logs

Keep logs as long as your plan says and your health department requires. Many kitchens keep them 6 to 12 months. Shellstock tags must be kept 90 days after the container is emptied, and parasite destruction records 90 days after the fish is sold or served. See HACCP verification and record keeping.

Paper log or digital log

Both work. The Food Code does not require a format.

Paper logs are cheap, need no training, and work when the internet is down. The downsides are illegible handwriting, missing pages, and logs filled in later from memory. Keep paper logs in a binder by month.

Digital logs on a tablet or phone can timestamp entries, require a reading before an item is marked accepted, and alert a manager when something is rejected. Some connect to Bluetooth probes, which removes transcription errors. The downside is cost and the need to export records for an inspector who wants to see them.

Whichever you use, the inspector needs to be able to read it on request. If you switch from paper to digital, keep the old paper logs for your retention period.

Common receiving log mistakes

Logging the truck instead of the food. The truck display shows air temperature. Probe the product.

Writing the same number every day. 38°F every delivery for three months suggests the readings are not real. Inspectors notice.

Using an uncalibrated thermometer. A probe reading 3°F low hides warm deliveries.

Logging after putting food away. Check before accepting. Once the driver leaves, you cannot reject.

No initials. Each entry needs the person who did the check.

Receiving temperature log limits under the Food Code

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The table summarizes the rules; read 3-202.11 for the exact wording. For shellstock, the Food Code and the National Shellfish Sanitation Program set specific receiving conditions, and the tag must be present.

How to take receiving temperatures

Use a calibrated probe thermometer. FSIS has a good explanation of probe types on its kitchen thermometers page. See the thermometer calibration log for how to check accuracy.

Packaged meat and poultry. Do not puncture vacuum packages if you can avoid it. Fold the package around the probe so the stem sits between two packages, or between the package and the product. If the reading is close to the limit, open one package and probe the product directly, then use that package first.

Bulk items in cases. Open the case and probe between items in the middle of the case, not at the edge where they warm first.

Milk and liquids. Open one container and probe the liquid, then use that container first. Or probe between two containers.

Frozen food. Check that it is frozen hard. Look for signs of thawing and refreezing: large ice crystals, frozen liquid at the bottom of the box, items stuck together, or stained packaging.

Hot food. Probe the center of the thickest part. Catered or commissary food should arrive at 135°F or above.

Shell eggs. The limit is air temperature, so you can check the temperature on the truck or place the probe between eggs in a case.

Live shellfish. Check that shells are closed or close when tapped, that there is a tag, and that the product is cold. Keep the tag with the container until it is empty, then file it for 90 days.

Receiving temperature log for specific foods

Raw meat and poultry

Check one case of each type. Ground meat is higher risk than whole cuts because bacteria from the surface are mixed through. If ground beef arrives at 44°F, reject it.

Fish

Fish species that can form histamine (tuna, mahi-mahi, mackerel, bluefish, amberjack and others) need tight temperature control from harvest. FDA's fish hazards guide treats temperature control as the main control. Reject scombroid species above 41°F. If you serve fish raw, check that the supplier provides parasite destruction records where required and keep them 90 days. See the seafood HACCP plan.

Dairy

Check one item per delivery. Look at dates and packaging.

Produce

Whole uncut produce is not usually TCS and does not have a receiving temperature limit under the Food Code. Cut leafy greens, cut tomatoes and cut melons are TCS and must arrive at 41°F or below. Sprouts are a higher risk item and should arrive cold.

Cooked food from a commissary

Hot food at 135°F or above, cold food at 41°F or below. Ask for the time the food left the commissary if you use time as a public health control.

Setting up the receiving area

Good receiving starts before the truck arrives:

• Schedule deliveries outside rush periods so someone has time to check.
• Clear space in the walk-in and freezer before the delivery.
• Have a thermometer, sanitizer wipes and the log at the receiving spot.
• Put cold and frozen food away first, then dry goods.
• Do not leave deliveries on the dock while you finish a ticket. A case of chicken sitting at room temperature for 40 minutes is the most common receiving problem, and it happens after the delivery, not before.

A receiving procedure staff can follow

Post this at the back door:

1. Stop what you are doing when the delivery arrives.
2. Check the invoice against the order.
3. Probe one refrigerated item, one frozen item, and every high risk item (raw oysters, scombroid fish).
4. Check packaging and dates.
5. Write the readings on the log.
6. Reject anything outside the limits and write the reason on the invoice and the log.
7. Put refrigerated and frozen food away within 15 minutes of checking. (A common house rule; set your own.)
8. Initial the log.

Receiving temperature log for food trucks and caterers

Food trucks often pick up supplies from a commissary or a warehouse club instead of getting deliveries. The same limits apply: check the temperature when you get the food back to your truck or commissary, and record it. Bring an insulated cooler with ice packs to the store, especially in summer. Caterers receiving rentals or specialty items at a venue should check those too.

See the food truck HACCP plan and the catering HACCP plan.

Recalls: using your traceability records

When a supplier or the FDA announces a recall:

1. Check the recall notice for product, brand, lot codes and dates.
2. Search your receiving records and invoices for matching lots.
3. Pull and segregate any matching product; label it "Recall, do not use".
4. Check prep labels for batches made with the product, and pull those too.
5. Follow the supplier's instructions for return or destruction, and keep proof.
6. Record what you found and what you did, with dates and names.

A kitchen with good records can do this in fifteen minutes. A kitchen without them throws everything away.

Build traceability into your receiving step

Traceability starts at the back door. The HACCP plan builder adds a receiving step with temperature checks, supplier approval and record keeping to your plan, and the restaurant temperature log has room for lot codes. Start free with one process; the plan is a draft for your health department to review. See also who produces the Food Code for how the retail rules fit with FSMA.

Frequently asked questions

What is traceability in food safety?

The ability to track food through the supply chain, one step back and one step forward, so that a contaminated product can be found and recalled quickly.

Does the Food Traceability Rule apply to restaurants?

Yes, for receiving foods on the Food Traceability List, such as leafy greens, tomatoes, fresh herbs, shell eggs, finfish and soft cheeses. Some small restaurants are exempt. Compliance is required from July 20, 2028.

What records does a restaurant need for traceability?

For listed foods: the traceability lot code, product description, quantity, the location it came from, the date received and the source of the lot code.

How long must traceability records be kept?

Two years under the Food Traceability Rule, and they must be produced within 24 hours of an FDA request.