Food safety doesn’t begin or end at the warehouse door. Every shipment introduces responsibilities for protecting product integrity, maintaining appropriate transportation conditions, and documenting how food moves through the supply chain. For food and beverage manufacturers, understanding those responsibilities is an important part of selecting carriers and managing transportation operations.

The Food Safety Modernization Act (FSMA) establishes requirements that affect how food is transported and how certain products are tracked through the supply chain. Two FDA regulations are particularly relevant to transportation operations: the Sanitary Transportation Rule and the Food Traceability Rule, commonly known as FSMA 204. Although they address different aspects of food safety, both have implications for carrier relationships, shipment documentation, and operational processes.

This guide explains the transportation-related requirements of each rule, the steps manufacturers can take to strengthen their carrier programs, and how to prepare for the Food Traceability Rule’s July 2028 compliance date. For a broader perspective on managing food distribution, explore our food and beverage logistics guide for mid-market manufacturers.

This article provides general information about food transportation requirements and is not legal advice. Manufacturers and logistics providers should consult their compliance teams and official FDA guidance to determine which requirements apply to their operations.

Understanding the Two FSMA Rules That Affect Food Transportation

FSMA strengthened the FDA’s approach to food safety by emphasizing prevention, accountability, and traceability throughout the supply chain. For manufacturers and logistics providers, two regulations have particular relevance to transportation activities.

The Sanitary Transportation Rule establishes requirements designed to prevent food from becoming unsafe during transportation by motor or rail vehicle. It addresses transportation equipment, operating practices, training, and recordkeeping, with responsibilities assigned to shippers, loaders, carriers, and receivers.

The Food Traceability Rule (FSMA 204) establishes additional recordkeeping requirements for foods included on the FDA’s Food Traceability List. It focuses on maintaining information that helps identify and trace affected products through specific supply chain events.

While the Sanitary Transportation Rule is already in effect, the FDA has established July 20, 2028, as the compliance date for the Food Traceability Rule.

These regulations serve different purposes. One focuses on sanitary transportation practices, while the other strengthens the ability to trace certain foods through the supply chain. Understanding that distinction helps manufacturers identify the appropriate responsibilities, processes, and documentation for their operations.

Sanitary Transportation Requirements and Carrier Responsibilities

The Sanitary Transportation Rule addresses the conditions under which food is transported and establishes responsibilities for the parties involved in moving it.

For food and beverage manufacturers, the rule makes carrier selection and clearly defined operating procedures especially important. Transportation arrangements should establish who is responsible for maintaining sanitary conditions, communicating product requirements, and documenting relevant activities.

The rule addresses several areas of transportation operations:

• Vehicles and equipment. Transportation equipment must be appropriate for its intended use and maintained in conditions that prevent food from becoming unsafe.
• Transportation operations. Applicable procedures address sanitary handling, temperature requirements, and practices intended to prevent contamination.
• Training. Carriers have training obligations under specified circumstances, including when they agree to responsibility for sanitary conditions during transportation.
• Records. Covered parties must maintain documentation required for their applicable responsibilities.

Written agreements can help establish accountability between shippers, carriers, loaders, and receivers before freight moves. They also provide a useful reference when questions arise about equipment condition, temperature requirements, or the handling of a shipment.

For additional guidance on evaluating transportation partners, see our food-grade transportation guide.

FSMA 204 Expands Food Traceability Requirements

While the Sanitary Transportation Rule focuses on protecting food during transit, the Food Traceability Rule introduces additional recordkeeping requirements intended to improve the speed and accuracy of food traceability.

The rule applies to covered activities involving foods on the FDA’s Food Traceability List. Businesses subject to the requirements must maintain specified key data elements associated with critical tracking events, including shipping and receiving.

Depending on the event, this information may include product identification, traceability lot codes, quantities, locations, and relevant dates.

For manufacturers and distributors, these requirements highlight the importance of accurate, accessible information throughout the supply chain. Transportation providers may contribute shipment information that supports a manufacturer’s broader traceability processes, even when the provider is not directly responsible for every required record.

The FDA has established July 20, 2028, as the compliance date for the Food Traceability Rule.

Manufacturers should work with their compliance teams to determine whether their products and activities fall within the rule’s scope and identify the information required from transportation and distribution partners.

Additional details and regulatory updates are available through the FDA’s FSMA resources.

Comparing Sanitary Transportation and Food Traceability Requirements

Although both regulations support food safety, they address different operational responsibilities. Understanding where transportation activities intersect with each rule can help manufacturers develop more effective compliance processes.

For logistics teams, the practical distinction is between maintaining appropriate transportation conditions and ensuring that necessary shipment information is available to support traceability.

Both require coordination, but the specific obligations depend on the products, activities, and responsibilities of the parties involved.

Evaluating Carriers for Food Safety and Compliance Readiness

A carrier’s experience transporting food products is an important qualification, but manufacturers should also understand the procedures and documentation supporting that experience.

Carrier evaluations should consider whether transportation partners can consistently meet product requirements, communicate exceptions, and provide the information necessary to support applicable compliance obligations.

Four areas deserve particular attention:

1. Documented transportation responsibilities

Carrier agreements should clearly establish responsibility for applicable sanitary transportation activities. Manufacturers should understand how equipment requirements, cleaning procedures, and other relevant operating conditions are communicated and documented.

2. Training and operational procedures

Carriers should be able to explain how personnel are trained to meet their assigned responsibilities and provide applicable documentation. Training expectations should reflect the carrier’s role and the requirements of the freight being transported.

3. Temperature management and exception response

For refrigerated and frozen products, manufacturers should confirm how temperature requirements are communicated, what monitoring capabilities are available, and how potential deviations are escalated.

4. Shipment information and record accessibility

Transportation partners should be able to explain what shipment data they collect, how it is shared, and how quickly relevant information can be retrieved when needed.

These discussions help manufacturers evaluate whether a carrier’s capabilities align with their food safety procedures and operational expectations.

EASE’s Approach to Food-Grade Transportation

EASE supports food and beverage manufacturers through a network of vetted, food-grade carriers and transportation capabilities designed to accommodate a range of product requirements.

Our services include temperature-controlled transportation with equipment operating from -20 to 70+ degrees, along with dry van capacity for products that do not require refrigeration.

EASE also provides access to FDA-certified and registered storage facilities and maintains ISO 9001:2015 certification as part of its broader quality management practices. More information about these capabilities is available on our food and beverage logistics page and in our food and beverage warehousing guide.

Visibility and communication are also important components of managing food-grade freight.

Through AMMI, EASE’s proprietary logistics intelligence platform, customers can access live shipment status, custom alerts, and reporting capabilities. These tools support communication and operational oversight throughout the transportation process.

Customers also have 24/7/365 access to an EASE team member, with an average response time of two minutes.

Because food safety and traceability requirements vary by product and operation, EASE works with customers to clarify transportation expectations and identify the shipment information available to support their programs.

Integrating Food Safety Requirements Into Daily Transportation Operations

Effective compliance depends on consistent execution. Even well-documented policies can fall short when transportation requirements are not incorporated into everyday carrier management and shipment planning.

Manufacturers can strengthen their transportation programs by establishing repeatable procedures across several operational areas.

• Maintain current carrier agreements. Keep relevant responsibilities, operating requirements, and supporting documentation accessible to the teams managing transportation.
• Communicate temperature requirements for every shipment. Appropriate setpoints and handling instructions should be established before freight is tendered rather than assumed from previous shipments.
• Coordinate with loading and receiving teams. Warehouses and receiving facilities play important roles in maintaining sanitary transportation conditions. Communication should extend beyond the carrier and shipper.
• Standardize shipment information. Establish consistent methods for collecting and sharing pickup details, delivery confirmations, and other information needed for transportation oversight and applicable traceability requirements.
• Review carrier performance regularly. Periodic evaluations should consider service performance, equipment suitability, applicable training documentation, and the handling of transportation exceptions.

Embedding these practices into carrier onboarding, shipment execution, and performance reviews can help reduce operational inconsistencies while supporting broader food safety objectives.

The specific procedures and documentation required under FSMA should be determined with the manufacturer’s compliance team.

Preparing Transportation Networks for the 2028 Traceability Deadline

Although the Food Traceability Rule’s compliance date is July 20, 2028, manufacturers should begin evaluating their transportation data and coordination processes well before the deadline.

Preparation starts with identifying which products and activities are subject to the rule. From there, manufacturers can assess how those products move through their distribution networks and where required information is generated, maintained, and exchanged.

Transportation-related preparation may include:

1. Identify applicable products. Work with compliance teams to determine which foods fall within the Food Traceability List and which activities trigger recordkeeping obligations.
2. Map transportation and receiving processes. Document how products move between facilities, carriers, distribution partners, and customers.
3. Evaluate available shipment data. Identify which transportation records are already accessible and where additional information or coordination may be necessary.
4. Review data-sharing arrangements. Confirm how logistics partners communicate relevant shipment information and whether existing processes support the manufacturer’s traceability needs.
5. Address gaps before implementation. Update procedures, partner expectations, and data workflows where necessary to support applicable requirements.

Early preparation gives manufacturers more time to coordinate with transportation providers and establish processes that work across their distribution networks.

For EASE customers, AMMI provides a shared source of shipment information that can support these conversations. Manufacturers should work with their compliance teams and EASE representatives to determine which available data is relevant to their specific traceability requirements.

Frequently Asked Questions

What is FSMA transportation compliance?

FSMA transportation compliance refers to meeting applicable FDA food safety requirements associated with transporting food. The Sanitary Transportation Rule addresses sanitary conditions and practices during transportation, while the Food Traceability Rule establishes additional recordkeeping requirements for certain foods and supply chain activities.

Who is responsible for sanitary transportation, the shipper or the carrier?

The Sanitary Transportation Rule assigns responsibilities to shippers, loaders, carriers, and receivers based on their respective activities and applicable arrangements. Carrier obligations can depend on responsibilities established through written agreements. Manufacturers should work with their compliance teams to clarify how these requirements apply to their transportation programs.

When is the Food Traceability Rule compliance date?

The FDA has established July 20, 2028, as the compliance date for the Food Traceability Rule. Manufacturers should consult the FDA’s official FSMA resources for updates and confirm whether their products and operations are subject to the requirements.

Where can manufacturers find official FSMA guidance?

The FDA provides regulatory information, guidance documents, and updates through its Food Safety Modernization Act website. Manufacturers should use these resources alongside qualified compliance or legal guidance when evaluating their obligations.

Building a More Reliable Food Transportation Program

Food safety compliance requires coordination across manufacturers, transportation providers, warehouses, and receiving facilities. Clear responsibilities, consistent operating procedures, and accessible shipment information help ensure that food safety requirements remain part of everyday logistics execution.

As manufacturers prepare for evolving traceability requirements, transportation partners should contribute reliable service, transparent communication, and the operational information needed to support effective oversight.

EASE helps food and beverage manufacturers manage these demands through vetted carrier networks, temperature-controlled transportation, real-time shipment visibility, and dedicated logistics support.

To learn more about our approach to food-grade transportation, contact EASE or explore our food and beverage logistics services.