The Food Traceability List, explained
The rule follows these foods. If you handle one of them, or a food that contains one as an ingredient in the same form, FSMA 204 can reach you.
The Food Traceability List (FTL) is the set of foods FDA identified as higher-risk, for which the extra records apply. It is the switch that turns the whole rule on: no FTL food, no new records. So the first question for any operation is whether anything it handles is on the list.
The list is organized into categories rather than a line for every product. As at July 12, 2026, the categories are:
| Category | What it includes |
|---|---|
| Cheeses, fresh soft and soft unripened | Cottage cheese, cream cheese, mozzarella, queso fresco, ricotta, made from pasteurized or unpasteurized milk |
| Cheeses, soft ripened and semi-soft | Brie, Camembert, blue, and similar |
| Shell eggs | Eggs still in the shell from domesticated hens |
| Nut butters | Peanut, almond, and other nut butters |
| Cucumbers (fresh) | Fresh cucumbers |
| Herbs (fresh) | Fresh culinary herbs |
| Leafy greens, fresh and fresh-cut | Whole and fresh-cut leafy greens |
| Melons (fresh) | Cantaloupe, honeydew, watermelon, and similar |
| Peppers (fresh) | Fresh peppers |
| Sprouts | All sprouts |
| Tomatoes (fresh) | Fresh tomatoes |
| Tropical tree fruits (fresh) | Mango, papaya, and similar |
| Fruits and vegetables, fresh-cut | Fresh-cut fruits, and fresh-cut vegetables other than leafy greens |
| Finfish (fresh and frozen) | Including smoked finfish |
| Crustaceans (fresh and frozen) | Shrimp, crab, lobster, and similar |
| Mollusks, bivalves (fresh and frozen) | Oysters, clams, mussels, scallops |
| Ready-to-eat deli salads | Potato salad, egg salad, pasta salad, coleslaw |
The ingredient rule catches more than you might think
The list does not stop at the listed foods themselves. It also reaches foods that contain a listed food as an ingredient, where that listed ingredient remains in the same form in which it appears on the list. A finished product that contains a fresh soft cheese, for example, can be caught because the cheese is still a fresh soft cheese inside it.
The pivot is the phrase "same form." If a listed food is processed so it is no longer the FTL food (for example a fresh vegetable that is cooked, or produce that receives a kill step and is transformed into something no longer on the list), the situation can be different, and a kill-step exemption may apply. This is exactly the kind of line that is easy to get wrong from the outside, which is why the determination should be made against your actual product and process.
Why the category framing matters
Because the list works by category, a food does not have to be named individually to be caught. If your product fits a category, treat it as covered until you have confirmed otherwise. Two operations handling what looks like the same commodity can also land differently: whole leafy greens and fresh-cut leafy greens are both on the list, but fresh-cut changes the events you are responsible for, and a food that is rarely consumed raw may fall under a separate exemption.
The list can change
FDA can add or remove categories. We treat the list as a dated snapshot and re-verify it against the FDA page on a schedule, and you should confirm the current list before you finalize any determination. The categories above reflect the list as at the date stamped on this page.
Related: Are you exempt? · What is FSMA 204?