If you’ve been following the news lately, food safety issues are everywhere – from listeria outbreaks to warnings about what not to eat at airports (a topic near and dear to my heart, as Anne loves to point out).
That’s why Anne and I recently sat down with Angela Fernandez, Senior Vice President of Market Development at GS1 US, to dive into what has to be my favorite acronym to say – FSMA (the Food Safety Modernization Act). It rolls off the tongue like you just ate a bag of Pop Rocks.
Here’s what you need to know from our conversation.
FSMA 101: What Is It and Why Should You Care?
First things first – what exactly is FSMA? As Angela explained, President Obama signed this sweeping food safety reform into law back in 2011, introducing 70 different policy and regulatory changes. What makes this significant is that it represented the first major overhaul of our food safety laws in nearly 75 years.
Before FSMA, the industry operated under the Bioterrorism Act’s “one up, one down” principle – meaning people in the food business needed to know from whom they bought, to whom they sold, and also what it was they were selling.
That’s it.
As numerous food safety recalls showed us (remember the spinach recall of 2006?), this approach wasn’t cutting it. It left us all wanting more, something no one has ever said after eating spinach, ever.
The most recent piece of FSMA to roll out is Rule 204, which focuses on additional traceability requirements. It officially became effective in January 2023, and the FDA just announced a 30-month extension for compliance. But as Angela warned – don’t think of this extension as a reason to cram the night before the test.
The Digital Evolution of Food Safety
One of the most interesting aspects of our discussion centered on how digital capabilities are transforming food safety practices. As Angela pointed out, many food businesses (especially smaller ones) still maintain records on paper – not exactly ideal when the FDA needs traceability information within 24 hours during a potential outbreak.
The new requirements include digital record-keeping components, with even a simple Excel spreadsheet considered a “minimum viable solution.” But the real challenge isn’t just digitizing records – it’s ensuring those digital records speak the same language across the entire supply chain.
Traceability Lock Codes: The New Standard
Two critical new requirements emerged from our discussion:
- Traceability Lock Code: A universal identifier that follows products through the supply chain
- Traceability Lock Code Source: Information about who created that code
The problem? When I track something in my operation, I might use internal codes that mean nothing to you when I ship you my products. This communication gap is what GS1 is working to solve through standardization.
The Million-Dollar Question: What’s the ROI?
When I asked Angela about the return on investment for all this traceability work, her answer was refreshingly candid: “I would actually say no, there is not [an ROI in traceability alone].”
The real value, she explained, comes not from traceability itself but from the end-to-end visibility it enables. Companies like Subway have discovered that implementing these standards allowed them to automate inventory management, saving an estimated 9,200 hours of labor annually – translating to over $100,000 in savings.
Similarly, Ocean Mist found they were saving 25-35% of crew time by digitizing their field operations, which also improved inventory rotation and reduced waste.
The takeaway? ROI doesn’t come from traceability – it comes from visibility.
What’s Next for Food Businesses?
With the FDA’s 30-month extension, companies have until 2028 to fully comply with the new regulations. But as Angela emphasized, this isn’t time to hit the snooze button. The extension gives the industry breathing room to address complex questions around implementation, especially considering FSMA affects 19 different food categories, each with unique requirements.
Her advice?
Stay the course with planned investments, conduct more pilots, and use the extra extension time to collaborate on solving implementation challenges.
Total Recall
What struck me most from our conversation was how FSMA should not be thought of as a regulatory burden but as a potential catalyst for modernization across the food supply chain. By forcing businesses to improve traceability, it’s inadvertently pushing digital transformation and creating opportunities for operational efficiencies that might otherwise have been overlooked.
Regulation often gets a bad rap but, if it moves us forward to a better, more standardized and more digitized place, I am all for it.
As someone who’s spent years covering retail innovation, I can’t help but see parallels to other industry-wide changes we’ve witnessed. Sometimes, the most transformative innovations come not from flashy new technologies but from solving fundamental operational challenges that affect everyone in the ecosystem.
If you’re in the food business, now’s the time to get educated and engaged. As Angela reminded us, compliance isn’t a competitive advantage – it’s a necessity. But how you implement these changes just might give you an edge in building a more visible, efficient, and ultimately profitable operation.
Want to learn more? Check out GS1US.org/foodsafety or listen to our full conversation with Angela on the Omni Talk Spotlight Series podcast.



Omni Talk® is the retail blog for retailers, written by retailers. Chris Walton and Anne Mezzenga founded Omni Talk® in 2017 and have quickly turned it into one of the fastest growing blogs in retail.