What Foods Are on the Food Traceability List?

The Food Traceability List (FTL) identifies the specific foods that require additional traceability records under FSMA 204. The list includes fresh produce, seafood, soft cheeses, shell eggs, nut butters, fresh herbs, sprouts, and ready-to-eat deli salads. Only the specific forms listed are covered -- frozen produce is generally excluded, but frozen seafood is covered. The FTL was developed using an FDA risk-ranking model that evaluated outbreak frequency, illness severity, contamination likelihood, and other factors.

How did the FDA select these foods?

The FDA used a risk-ranking model evaluating "commodity-hazard pairs" across seven criteria:

1. Frequency of outbreaks and occurrences of illness
2. Severity of illness
3. Likelihood of contamination
4. Potential for pathogen growth during manufacturing/processing
5. Manufacturing process contamination probability
6. Consumption rate
7. Cost of illness

Foods scoring in the "moderate to strong" range were selected. The model underwent two independent external peer reviews.

Cheese and dairy

| Food | Forms Covered | Excluded Forms | |------|--------------|----------------| | Fresh/soft cheese (pasteurized milk) -- cottage, chevre, cream cheese, mascarpone, ricotta, queso blanco, queso fresco, queso de crema, queso de puna | All fresh/refrigerated | Frozen, shelf-stable, aseptically processed | | Soft ripened/semi-soft cheese (pasteurized milk) -- brie, camembert, feta, mozzarella, blue/gorgonzola, brick, fontina, monterey jack, muenster | All fresh/refrigerated | Frozen, shelf-stable | | All cheese from unpasteurized milk (except hard cheese) | All non-hard varieties | Hard cheese, frozen, shelf-stable, aseptically processed |

Shell eggs

| Food | Forms Covered | Excluded Forms | |------|--------------|----------------| | Shell eggs (domesticated chicken only) | All | Non-chicken eggs, liquid/dried egg products |

Only intact shell eggs from domesticated chickens are covered. Liquid eggs, dried egg products, and eggs from other species (duck, quail) are not on the FTL.

Nut butters

| Food | Forms Covered | Excluded Forms | |------|--------------|----------------| | Nut butters -- almond, cashew, coconut, hazelnut, macadamia, peanut, pecan, pistachio, walnut, and all other tree nut butters | Shelf-stable, refrigerated, frozen | Soy butter, seed butters (sunflower, tahini) |

Nut butters are unusual on the FTL because shelf-stable forms are covered. Most other FTL categories exclude shelf-stable products.

Fresh produce -- vegetables

| Food | Forms Covered | Excluded Forms | |------|--------------|----------------| | Leafy greens -- arugula, butter lettuce, chard, chicory, endive, escarole, green leaf lettuce, iceberg lettuce, kale, red leaf lettuce, romaine, pak choi/bok choi, sorrel, spinach, watercress | Fresh, whole and cut | Whole head cabbage, banana/grape leaves, tree-grown leaves, herbs (dill, collards) | | Fresh-cut leafy greens (single ingredient and mixed) | Fresh-cut | -- | | Cucumbers (all varieties) | Fresh | Pickled, processed | | Peppers (all varieties) | Fresh | Dried, processed | | Fresh-cut vegetables (non-leafy) | Fresh-cut | -- | | Sprouts (all varieties) -- alfalfa, bean, broccoli, clover, radish, and mixed | Fresh | -- |

Fresh produce -- fruits

| Food | Forms Covered | Excluded Forms | |------|--------------|----------------| | Melons -- cantaloupe, honeydew, muskmelon, watermelon | Fresh | Frozen, processed | | Tomatoes (all varieties) | Fresh | Canned, processed | | Tropical tree fruits -- mango, papaya, guava, lychee, jackfruit, starfruit, mamey | Fresh | Banana, pineapple, avocado, citrus, pit fruits, tree nuts, figs | | Fresh-cut fruits (all types) | Fresh-cut | Certain exempt varieties per 21 CFR 112.2(a)(1) | | Fresh herbs -- parsley, cilantro, basil | Fresh | Dill, dried herbs, other herbs per 21 CFR 112.2(a)(1) |

Note: Bananas, pineapples, avocados, citrus fruits, and pit fruits are not on the FTL.

Seafood -- finfish

| Food | Forms Covered | Excluded Forms | |------|--------------|----------------| | Histamine-producing finfish -- tuna, mahi mahi, mackerel, amberjack, swordfish, yellowtail | Fresh, frozen, previously frozen | Catfish (USDA jurisdiction) | | Ciguatoxin-risk finfish -- grouper, barracuda, snapper | Fresh, frozen, previously frozen | -- | | Other finfish -- cod, haddock, pollock, salmon, tilapia, trout, and others | Fresh, frozen, previously frozen | Catfish | | Smoked finfish (cold and hot smoked) | Refrigerated, frozen, previously frozen | -- |

Important: Unlike produce, seafood on the FTL includes fresh, frozen, AND previously frozen forms. Frozen fish is covered.

Seafood -- shellfish

| Food | Forms Covered | Excluded Forms | |------|--------------|----------------| | Crustaceans -- shrimp, crab, lobster, crayfish | Fresh, frozen, previously frozen | -- | | Molluscan shellfish bivalves -- oysters, clams, mussels | Fresh, frozen, previously frozen | Scallop adductor muscle; raw bivalves under NSSP/21 CFR 123/1240.60 |

Prepared foods

| Food | Forms Covered | Excluded Forms | |------|--------------|----------------| | Ready-to-eat deli salads -- egg salad, potato salad, pasta salad, seafood salad | Refrigerated (includes those frozen during supply chain) | Meat-containing salads (USDA jurisdiction) |

What is the "contains" rule?

Foods that contain an FTL food as an ingredient are also covered by FSMA 204, but only if the listed food remains in the same form as it appears on the FTL.

Examples:

• A fresh salad containing romaine lettuce -- covered (romaine is fresh, same form as FTL listing)
• A frozen pizza with mozzarella -- not covered (frozen form is excluded for mozzarella on the FTL)
• A wrap made with fresh spinach and fresh tomatoes -- covered (both ingredients are in their FTL-listed forms)

The "contains" rule means a wide range of multi-ingredient products may be covered if they include an FTL food in its listed form.

What is the kill step rule?

A kill step is lethality processing that significantly minimizes pathogens -- cooking to safe temperature, pasteurization, canning, or similar processing.

If an FTL food undergoes a kill step such that it no longer retains its original listed form, downstream handlers are exempt from traceability requirements for that food. However, handlers before the kill step must still comply.

Critical for restaurants: The kill step exemption does not exempt you from recording Receiving KDEs for raw FTL foods. A restaurant receiving raw salmon must still record receiving data, even though the salmon will be cooked. The exemption applies to foods that arrive already processed through a kill step.

Why does form matter?

The specific form listed on the FTL determines coverage:

| Form Rule | What It Means | Example | |-----------|---------------|---------| | "Fresh" | Not frozen, canned, dried, or otherwise processed | Fresh tomatoes are covered; canned tomatoes are not | | "Fresh-cut" | Product has been cut, shredded, or sliced | Pre-cut fruit mix is covered | | Frozen seafood IS covered | Unlike produce, seafood coverage includes frozen | Frozen shrimp is covered; frozen strawberries are not | | Shelf-stable nut butters ARE covered | Unlike most categories | Peanut butter in a jar is covered |

Which FTL foods are most common in restaurants?

Nearly every restaurant handles multiple FTL foods daily. The most common:

Very common in restaurants:

• Leafy greens (romaine, spinach, mixed greens, kale)
• Tomatoes (fresh)
• Cucumbers and peppers (fresh)
• Fresh herbs (basil, cilantro, parsley)
• Shell eggs
• Finfish (salmon, tuna, cod, snapper, trout)
• Crustaceans (shrimp, crab, lobster)
• Soft cheeses (mozzarella, feta, ricotta, cream cheese)
• Melons (cantaloupe, honeydew, watermelon)
• Fresh-cut fruits and vegetables

Also common in some restaurants:

• Tropical fruits (mango, papaya)
• Bivalves (oysters, clams, mussels)
• Smoked fish
• Deli salads
• Nut butters
• Sprouts

The question for most restaurants is not whether they handle FTL foods, but how many and how often.

Can the Food Traceability List change?

Yes. The FTL is not static. The FDA can modify it through a defined process:

1. Federal Register notice proposing changes
2. Public comment period
3. Second Federal Register notice finalizing changes
4. Additions become effective 2 years after the final notice
5. Deletions are effective immediately

The FDA has signaled that the list will likely grow over time as more commodity-hazard pairs are evaluated.