Food traceability for pizzerias: the FDA rule and what to keep now
A pizzeria should be able to say which supplier every ingredient came from and when it arrived. For certain foods, the FDA’s Food Traceability Rule (FSMA section 204) will make that a federal record-keeping requirement for restaurants, but Congress has told the FDA not to enforce it before July 20, 2028. Until then, keep invoices, keep lot numbers and label everything you repackage.
What the federal rule asks for
The Food Traceability Rule covers foods on the FDA’s Food Traceability List, which includes many fresh fruits and vegetables, fish, shellfish, eggs, some cheeses and nut butters. Businesses that handle those foods have to keep Key Data Elements at each Critical Tracking Event; for a restaurant, that mostly means receiving: what came in, from whom, when and with what lot code.
Restaurants get some relief. They don’t have to assign their own traceability lot codes to what they receive, and the rule fully exempts small restaurants and retail food establishments below a threshold set in 21 CFR 1.1305. Covered businesses must be able to hand the FDA their records, as a sortable spreadsheet when asked, within 24 hours during an outbreak or recall.
The original compliance date was January 20, 2026. In late 2025 Congress directed the FDA not to enforce the rule before July 20, 2028, and the agency said it would comply. Use the time to build the habit, not to ignore it.
What to keep in practice
| Product | Keep | Common practice |
|---|---|---|
| Mozzarella, ricotta, fresh produce, eggs | Invoice plus the label or a photo with the lot number | At least as long as your distributor’s records |
| Flour, canned tomatoes, oil | Invoice, lot number when you open a case | Long-life products: keep for years |
| Frozen food | Invoice, label | Past the best-by date |
| Made in-house (sauce, cooked toppings) | Your own label: item, date made, discard date | Until used or thrown out |
FDA Food Traceability Rule (21 CFR Part 1, Subpart S). Retention periods in the right-hand column are working practice, not the rule’s text.
The easiest method is a photo: snap the label when you open a case and keep the photos in a folder for each month. It beats a shoebox of peeled-off stickers nobody will ever read.
The labels you make yourself
This is where pizzerias fall short most often. Once a product leaves its original packaging, shredded mozzarella, sauce moved out of a #10 can, sliced ham, the manufacturer’s label no longer travels with it. The container needs its own label with the item name, the date it was opened or made, and the discard date. Under the Food Code, ready-to-eat TCS food held more than 24 hours needs that date mark anyway.
For dough, note the flour lot in your mixing log. Flour recalls do happen, and it is the only way to know which trays are affected.
Traceability and allergens
Keeping labels is also how you answer a customer with a food allergy: the ingredients of a bought-in pesto or hot honey are only on the package. The allergen rules for restaurants
Labels and records are among the first things an inspector looks at: see what happens during a health inspection.