May 22, 2026
Foodservice & Commissary Operators: How do I manage Traceability Data if I don't have capable Electronic Systems?
When all else fails you may be stuck with manual approaches to traceability. These can be painful and they often illustrate quite clearly why a capable electronic system is preferred. But don't underestimate the transition to use of a system or systems.


This is a question we are encountering with growing frequency as we engage with more clients in the foodservice space. Most organization we work with have one or more electronic systems for managing the business.
However the challenge is often that these systems aren't designed with traceability and lot-based ingredient management in mind. For example:
- Can they capture product identifiers, best before dates and lot codes at receiving? Some systems we've seen permit lot code capture, but the staff member has to manually enter it. Others can capture this data from case label barcodes, but it is siloed in the receiving log and inaccessible for use in preparing new foods.
- Can you automatically assign a lot code to foods that are prepared that links back to the supplier's lot code, such as sliced peppers, when not part of a continuous process? This has been where we see some of the biggest gaps in systems capabilities. This lack of capability then balloons as an issue for more complex transformations where multiple traceable ingredients are used in creating a new food.
- What happens when a supplier fails to provide data on case labeling and/or the invoice? While some systems enable the master data manager to set a flag for items that need to be traced, the system itself cannot invoke a corrective action for follow up with the supplier. Or, when receiving from a FSMA Rule 204 Exempt Supplier, the system is incapable of permitting the staff member to assign a lot code for a traceable item.
- Is the system aligned with global standards for data semantics and syntax? While we do see some systems as having the flexibility to align to GS1 and other international standards, some invoke strange and unexplainable rules. For example one of the largest ERP platforms globally has a module designed for traceability that can only accept lot codes of 10 or less alphanumeric characters. In others the date code formats do not align to global standards which places additional burdens on the foodservice staff to ensure the data they share with trading partners is aligned with standards-based requirements.
- Why doesn't my existing system support lot-based ingredient management? We have a client using a well known ERP to run their foodservice operation. While it's a sophisticated platform, enabling many necessary capabilities for business operation, it requires considerable re-configuration to manage data needed and created during product transformations. This client, we feel, would be better off just selecting an additional system that handles traceability and let their ERP do what it already does a good job of.
So you're hopefully now understanding why traceability, even just lot tracking, is a challenge for the food industry. These systems capability gaps are shared across the spectrum of software systems from the smallest to the largest names in SaaS.
So what should foodservice and commissary operators do to achieve new traceability capabilities and earn the value that comes from better internal supply chain visibility?
Make a plan.
- Know that you should continue to focus on what you do best - making quality food that delights your customers.
- Don't go it alone. Where you lack expertise, engage with tech-agnostic experts like us at MDB. We help demystify traceability and help you uncover opportunities for process and systems improvements. We also have extensive experience in working with electronic systems and can help you navigate the evaluation and selection process.
- While regulations like FSMA Rule 204 may be forcing you to take action, approach as building in capabilities to run your business better with less expense and safer products. There is value to be won.
- Talk to your suppliers and customers. Supplier engagement is one of the most under-served areas of organizational transformations. They are often key to your success, so shouldn't be over-looked. And know what your customers expectations are for traceability. In some instances they may be willing to partner with you on the investment in new capabilities and shared advantage.
When all else fails you may be stuck with manual approaches to traceability. These can be painful and they often illustrate quite clearly why a capable electronic system is preferred. But don't underestimate the transition to use of a system or systems. At MDB we excel at this type of organizational transformation whether you're operating a single kitchen or a multi-national brand.
Reach out today.
FSMA Rule 204 commissary traceability
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