Are bottled sauces and dried spices covered by the FDA Food Traceability Rule? What the list includes, the 2028 date and the records to plan.

Mostly no. Dried spices, bottled sauces and other condiments are not on the FDA Food Traceability List. The rule matters when a product contains a listed food, such as fresh peppers or fresh herbs, that stays in the same fresh form. FDA will not enforce it before 20 July 2028.

FDA's Food Traceability Rule (FSMA Section 204) applies to US and "foreign firms producing food for U.S. consumption", according to the agency's rule page, last updated on 4 November 2026. For a Vietnamese sauce exporter or a US importer the real question is narrower: which of your SKUs fall inside the list, and what records would a covered product need? This article answers both from FDA's own pages.

1. What is the latest on the FDA Food Traceability Rule?

Enforcement has moved to 20 July 2028. The original compliance date was 20 January 2026. FDA proposed a 30-month extension to 20 July 2028 in the Federal Register on 7 August 2025, and Congress then directed the agency not to enforce the rule before that date; FDA says it intends to comply. The same page lists a public meeting on lot-level traceability on 6 November 2026.

One practical warning: at the time of writing, the "getting started" box on the same FDA page still shows the old January 2026 date. Read the whole page, not a single line, before you brief your team or a supplier.

2. Are sauces and dried spices on the Food Traceability List?

No. The list is built around fresh produce, seafood, shell eggs, nut butters, some cheeses and refrigerated deli salads. No dried spice, sauce or condiment category appears on it. The table below summarises the FDA list page for the product types Vietnamese exporters ship most.

Food category	On the list?	Note from FDA's list page
Fresh peppers (chilli included)	Yes	All varieties of fresh peppers
Fresh herbs	Yes	For example parsley, cilantro, basil; dill is exempt
Fresh-cut fruit and vegetables, cucumbers, leafy greens, melons, sprouts, tomatoes, tropical tree fruits	Yes	Fresh or fresh-cut forms
Finfish (including smoked), crustaceans, molluscan shellfish	Yes	Some raw bivalves are exempt
Shell eggs, nut butters, certain soft cheeses, refrigerated ready-to-eat deli salads	Yes	Shelf-stable cheeses are excluded
Dried spices and dried herbs (pepper, chilli powder, cinnamon)	Not listed	The herb entry covers fresh herbs only
Bottled or canned sauces, dipping sauces, marinades, hotpot bases	Not listed as a category	Check fresh listed ingredients (section 3)

Technician in gloves measuring an empty metal can with a digital caliper next to a screen showing three OK results

A technician measures an empty can with a digital caliper while a screen shows three OK checks (Illustrative photo).

3. Does the rule cover a sauce made with fresh chilli or herbs?

Only when the listed ingredient stays in the same form. FDA's list page says the requirements also apply to foods that contain listed foods as ingredients, provided the listed food "remains in the same form (e.g., fresh)". A chilled dipping sauce with chopped raw herbs is therefore a different case from a shelf-stable chilli sauce in which the fresh chilli has been cooked.

FDA's two pages do not give a worked example for cooked sauces. The exemptions sit in 21 CFR 1.1305, which includes provisions for foods that go through a kill step, and FDA links an online tool for checking exemptions. Ask the importer's regulatory adviser to confirm each borderline SKU in writing.

4. What records would a covered product need?

Covered firms keep Key Data Elements for each Critical Tracking Event and link them with a traceability lot code. FDA's rule page lists these events:

harvesting, cooling before initial packing, and initial packing;
first land-based receiving (for food from fishing vessels);
shipping, receiving and transformation (manufacturing or changing a food when the output is on the list).

The lot code is assigned at initial packing, first land-based receiving or transformation, and must not be changed at shipping. Records must be available within 24 hours of an FDA request, and during an outbreak or recall FDA can ask for an electronic sortable spreadsheet within 24 hours. Each covered firm also needs a written traceability plan; FDA sets no fixed format for it.

5. Practical checklist for importers and exporters

Map every SKU against the Food Traceability List and record the result, including "not listed".
Flag fresh listed ingredients (fresh chilli, fresh herbs, fresh-cut vegetables) and note whether they stay fresh in the finished product.
Agree one lot-code format that appears on the carton, the packing list and the batch test report, so one code links all three.
Run a 24-hour drill: pick a past shipment and see how long it takes to pull its lot, production date and test results.
Keep the date in view: 20 July 2028 is the enforcement start, and FDA's page is still being updated.

6. What this means for importers and brands

For most shelf-stable Vietnamese sauces and dried spices the rule is not a direct obligation, but buyers will keep asking for lot-level links between shipment, batch and test report. Building that into the documents buyers usually request from a Vietnamese sauce supplier is cheaper than adding it under pressure. Products with fresh components, such as some chilled Vietnamese dipping sauces, deserve a closer SKU-by-SKU review.

CiCook's facility is registered with the US FDA, certified to ISO 22000:2018 and HACCP, and every batch ships with a COA. More on that set-up is in our page on FDA-registered, ISO 22000 seasoning manufacturing for the US and EU.

FAQ

Is fish sauce covered by the FDA Food Traceability Rule?

Fish sauce is not named on the list. Finfish and smoked finfish are, so ask your regulatory adviser to confirm how a sauce made from fish is treated before you assume it is out of scope.