Engaging FDA on Traceability Shouldn’t be “Pay to Play”

FDA’s February 2026 announcement related to food traceability contained a concerning, and to the best of my knowledge, unprecedented statement indicating that the only listening session scheduled prior to the close of the comment period for the draft guidance will be limited to paying members of the Partnership for Food Traceability. 

To be clear: The Partnership for Food Traceability (PFT) serves a useful purpose. [I’ll refrain from side commentary on the IFT Global Food Traceability Center abandoning its historical role of serving as a neutral convenor for such conversations…].  A mechanism to convene companies to share learnings and explore solutions is necessary. The ‘flexibility’ afforded by the rule can quickly become chaos without an organizing body that can align the industry around process. 

As background, as part of the 2026 appropriations bill, Congress directed FDA to have quarterly listening sessions with stakeholders. 

How did PFT become the exclusive coordinator of listening sessions? This is not clear. Having worked for IFT early in my career, I know the competitive process that resulted in a contract awarded to IFT through which the traceability pilots required by FSMA were conducted. During the pilots, and in other related IFT work funded through FDA contracts, there was never a stipulation that a participant needed to be an IFT member. In the early days of FSMA, the Robert Wood Johnson Foundation funded Pew to hold roundtables. Although these were invite-only, there were no prerequisite strings attached to participation; individuals were invited on their own merit, ultimately involving over 200 people and developing over 30 documents. A more recent model used by FDA has been to task the Reagan-Udall Foundation to conduct traceability round tables. Having been established by Congress to do work to benefit FDA, it’s logical that FDA would use this mechanism. In contrast, the process by which PFT was appointed by FDA to manage listening sessions is unknown. More concerning, however, is that engagement with FDA will initially be restricted to PFT members. 

A look at PFT membership shows that there are only about 10 food companies that are members, and not a single produce company is a member despite a disproportionate number of fresh produce items being included on the Food Traceability List. The companies that are members are those that can afford to pay PFT dues. They are not representative of the breadth of industry members that will need to comply with the rule. 

Whether it was FDA or PFT leadership that suggested that the first listening session be a ‘PFT member benefit’ is unknown. But it’s in extremely poor taste and reflects poorly on both the Agency and PFT. PFT’s website boasts “unique access to collaboration with FDA”. FDA is a taxpayer funded agency and should engage with all stakeholders, not just PFT.