What Is the Receiving CTE?
The Receiving CTE is the traceability event triggered when a business takes possession of Food Traceability List (FTL) food after transportation from another location. For restaurants, this is the only Critical Tracking Event that applies under FSMA 204. It requires recording 8 Key Data Elements for every delivery of covered food (Source: 21 CFR 1.1345).
What are the 8 required Key Data Elements?
| # | Key Data Element | Where to Find It | |---|-----------------|------------------| | 1 | Traceability Lot Code (TLC) | Case labels, delivery invoices, packing slips | | 2 | Product description | Product name, brand, and size on the invoice | | 3 | Quantity and unit of measure | Count or weigh at receiving | | 4 | Previous source name and location | Distributor or supplier info on the invoice | | 5 | Receiving location description | Your business name and address | | 6 | Date received | Date of delivery | | 7 | TLC source location or reference | Packer or processor info on delivery documents | | 8 | Reference document type and number | Invoice number, bill of lading, or PO number |
Most of this information is already on your delivery invoices. Items 4, 5, and 6 are things you already know -- your regular supplier, your restaurant address, and today's date. Items 1, 2, 3, 7, and 8 appear on delivery documents or case labels.
The practical work is keeping delivery documentation organized and accessible for 2 years.
Why is the Receiving CTE the restaurant CTE?
Restaurants sit at the end of the supply chain, right before food reaches consumers. Under FSMA 204, restaurants do not harvest, cool, pack, ship, or transform food in ways that require traceability documentation. They receive it and serve it.
The Receiving CTE is essentially bookkeeping. It ensures that if the FDA traces a contaminated product forward through the supply chain, the trail does not go cold at the restaurant loading dock.
What do restaurants NOT have to do?
| Requirement | Required for Restaurants? | |------------|--------------------------| | Assign new Traceability Lot Codes | No | | Track transformation (cooking food) | No -- for food sold directly to consumers | | Maintain shipping records | No -- for direct consumer service | | Create farm maps | No | | Track harvesting events | No | | Track cooling events | No | | Track initial packing | No | | Install temperature sensors for FSMA 204 | No -- Receiving is a paperwork CTE |
Restaurants have the lightest compliance burden of any entity in the FSMA 204 supply chain.
What happens when receiving from non-regulated sources?
When a restaurant receives FTL food from a source that is not required to assign a TLC (for example, a small farm below the $250,000 threshold), the general rule is that the receiver must assign a TLC themselves (Source: 21 CFR 1.1345(b)).
However, restaurants and retail food establishments are exempt from this requirement. If your supplier does not provide a TLC, you are not required to create one. You should still record as much information as possible and note the absence of a TLC in your records.
By the July 2028 compliance date, most regulated suppliers should be providing TLCs on their delivery documents.
Are restaurants exempt from TLC assignment?
Yes. Restaurants never need to assign Traceability Lot Codes under FSMA 204. TLCs are assigned at three specific points in the supply chain:
- Initial Packing -- by the first packer of a raw agricultural commodity
- First Land-Based Receiving -- by the first person receiving seafood from a fishing vessel
- Transformation -- by the entity that manufactures or processes the food
Restaurants do none of these things (unless they operate a commissary -- see below). Restaurants receive existing TLCs, record them, and stop there.
What about restaurant commissaries?
This is the critical exception. If a restaurant operates a commissary or central kitchen that transforms food and ships it to satellite locations, the commissary is treated as a food processor under FSMA 204 (Source: 21 CFR 1.1350).
The commissary must:
- Maintain Receiving KDEs for FTL foods received
- Track Transformation KDEs -- link input TLCs to output TLCs and assign new TLCs
- Maintain Shipping KDEs for each shipment to satellite locations
- Satellite locations must maintain Receiving KDEs for food received from the commissary
This significantly increases the compliance burden for multi-unit operators with central production facilities.
What about farm-direct and ad hoc purchases?
Farm-direct purchases: If you buy food directly from a farm that grows and sells it, you only need to maintain the farm's name and address for 180 days. Full Receiving KDEs are not required.
Ad hoc purchases: When purchasing from another restaurant or retail establishment outside your normal supply chain, simplified requirements apply. Record the product name, date of purchase, and seller's name and address. Full KDEs are not required.
How long must Receiving CTE records be kept?
All Receiving CTE records must be retained for 2 years (24 months) from the date created. Records can be paper, electronic, or true copies (Source: 21 CFR 1.1455).
When the FDA requests records -- particularly during an outbreak investigation -- you must produce them within 24 hours. Restaurants with annual food sales exceeding $1,000,000 must provide records in electronic sortable spreadsheet format.
Can a distributor maintain records on my behalf?
Yes. Third-party record maintenance is allowed under the rule (Source: 21 CFR 1.1455). Your distributor can maintain Receiving CTE records on your behalf.
However, you remain legally responsible. If the FDA requests records and your distributor cannot produce them within 24 hours, the liability falls on you. Ensure you have a clear agreement specifying what records your distributor maintains and how you access them.