· Diego Martínez Núñez · FSMA 204 · 2 min read
FSMA 204 and EUDR: a strategic pause for Latin America
An opportunistic urgency for traceability in Latin America in the face of new global regulations.
The regulatory context
Latin America faces a defining moment in food traceability. Two key regulations are reshaping the game for the region’s exporters.
FSMA 204 (United States)
The FDA requires companies that produce, pack or store high-risk foods to keep additional traceability records. This includes:
- KDEs (Key Data Elements) — information that must be tied to every lot
- CTEs (Critical Tracking Events) — events that must be recorded across the chain
- TLCs (Traceability Lot Codes) — unique codes per product lot
The compliance date was extended to July 20, 2028 — but this isn’t a pause, it’s a strategic window.
EUDR (European Union)
The EU Deforestation Regulation requires due diligence to show products do not come from land deforested after December 2020. It affects 7 key commodities: coffee, cocoa, soy, palm oil, timber, rubber and cattle.
The opportunity for Latin America
Latin American exporters that adopt traceability technology now will be better positioned to access the world’s most demanding markets.
The FSMA 204 extension to 2028 should not be read as an excuse to postpone — companies that arrive at that date with robust digital systems will have competitive advantage over those that start late with patched solutions.
What to do now
- Map your chain — identify Critical Tracking Events and points where data is lost today
- Digitize capture — replace paper sheets or Excel with mobile forms
- Standardize the data — CTEs/KDEs per FSMA 204, DDS per EUDR
- Integrate blockchain — immutable records as audit evidence
Conclusion
Regulation won’t walk back. The question is whether you reach 2028 with a system proven in production — or rushing a last-minute workaround.
