What Can We Infer About Food Loss and Waste from FSMA Rule 204? More Than You Might Think

What Can We Infer About Food Loss and Waste from FSMA Rule 204? More Than You Might Think.

When people first read FSMA Rule 204, one question naturally comes up:

“Does the FDA want to know amounts of food loss and waste as part of the Electronic Sortable Spreadsheet?”

The short answer is simple:
No. FSMA Rule 204 does not require companies to track or report food loss or food waste.

The sortable spreadsheet (ESS) includes zero Key Data Elements (KDEs) related to shrink, spoilage, discard, trim, yield loss, or waste streams. Not a single KDE requires it.

But here’s where things get interesting:
Even though the rule does not regulate food waste, it will absolutely shine a light on it.

And that’s where the opportunity lies.

 FSMA 204 Isn’t a Waste-Reporting Rule — But It Will Reveal Waste

Let’s break down why.

1. Traceability exposes operational blind spots.

By design, Rule 204 requires more granular visibility into how food moves through a facility.
You must track:

• what you received,
• what you transformed,
• what you shipped,
• and in what quantities.

When you have those data points clearly defined, discrepancies become impossible to ignore.
If a transformation step consistently yields less finished product than expected, something is happening — and that “something” is usually food loss.

FSMA 204 isn’t asking for waste data, but it creates a digital environment where waste becomes visible.

2. Better inventory precision highlights shrink.

FSMA 204 introduces discipline in documenting lot codes, quantities, and movement events.
Inconsistent or incomplete data causes traceability failures, so companies tighten controls.

Once those controls are tightened, they often discover:

• over-trimming
• unreported spoilage
• miscounts
• mis-picks
• outdated FIFO practices

Again, Rule 204 doesn’t regulate any of it — but the visibility naturally brings it to the surface.

3. Traceability prevents waste through fewer broad recalls.

This one is rarely talked about.

Better traceability = narrower recall scopes.
If you can isolate affected lots within minutes, you don’t need to recall entire days or lines of production.

The greatest food waste reduction lever in the entire rule is precision.

4. The rule aligns with national food waste reduction goals — quietly.

FDA, USDA, and EPA have all committed to reducing food loss and waste by 50% by 2030.
FSMA 204 isn’t labeled as a “sustainability rule,” but better tracking supports:

• reduced spoilage
• better cold chain management
• improved forecasting
• reduced expiration destruction
• quicker identification of quality failures

It’s a compliance rule that inadvertently reinforces sustainability outcomes.

So let’s answer the core question directly:

Does the FDA want to know amounts of food loss and waste as part of the ESS?

No. Absolutely not.

The ESS is strictly an investigative tool for traceability.
It captures:

• lot code
• quantity produced
• quantity received
• quantity shipped
• transformation relationships
• supply chain actors

And nothing more.

The FDA does not expect you to report discarded product, spoiled product, trim quantities, or waste streams.

Those aren’t CTEs. They aren’t KDEs. They aren’t part of the rule.

But here’s the big takeaway: FSMA 204 will give companies unprecedented clarity into their own waste.

And the smart companies will use that.

Rule 204 is an obligation — but also an opportunity:

• identify where waste is occurring
• quantify losses
• improve yields
• standardize processes
• protect margins
• support sustainability goals
• reduce recall impact
• modernize food operations

This is where the compliance journey becomes a competitive advantage.

Conclusion: The Rule Doesn’t Ask for Waste Data — But It Reveals It

FSMA 204 is not a food waste reporting rule.
It doesn’t mandate tracking of spoilage, loss, trim, or shrink.
The ESS contains none of those fields.

But the traceability infrastructure companies build —
the lot tracking, the data discipline, the transformation documentation, the visibility —
will expose inefficiencies they couldn’t previously quantify.

And that might be one of the most valuable “unwritten benefits” of the entire rule.

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