FSMA and beyond: Why smart traceability and reusable packaging are non-negotiable

For decades, the food industry has relied on a simple model—produce, ship, sell, discard. But that model isn’t holding up anymore, strained from changes like the emerging FSMA 204 obligations that require businesses to track food from farm to table and Extended Producer Responsibility (EPR) laws that shift the financial burden of packaging waste to businesses.

To meet these changes, businesses can’t just tweak their existing processes. They’ve got to fundamentally reconsider how they approach packaging and traceability. 

We spoke with three industry leaders on how this is impacting the industry:

• Peter Jackson, Global Market Development Manager for RFID Food at Avery Dennison, explains why traceability is critical not just for compliance, but for protecting brand trust and financial stability.
  
• Tim Debus, President & CEO of the Reusable Packaging Association,  discusses how EPR laws are pushing companies toward reusable packaging at a time when sustainability is becoming a business priority.
  
• Dr. Karin Witton, Global Head of Sustainability at Tosca,  explains why reusable packaging isn’t just about cutting waste—it’s about lowering costs, improving operations, and staying ahead of regulatory changes.

From mandates to mangoes: Traceability isn’t optional anymore

For decades, traceability was more of an administrative function than anything else—important for audits, but not regarded as an activity that improved business operations. 

To put it simply, times have changed. Yet many companies still rely on batch scanning and paper-based tracking systems, which are slow, prone to errors, and inefficient. 

These outdated methods create significant risks:

• Financial risks: When recalls happen, companies often pull entire shipments or product lines because they lack the ability to pinpoint affected goods. This drains revenue, creates product waste, and jeopardizes supply.
  
• Competitive risks: Retailers demand greater transparency, putting pressure on suppliers to provide real-time traceability data. Companies that fail to meet these expectations may end up losing contracts to competitors who can.
  
• Regulatory and legal risks: Food safety risks are growing, and without digital traceability, businesses face higher exposure to regulatory penalties, legal action, and reputational damage. 

Peter Jackson, who has spent years working on RFID solutions, sees FSMA’s traceability mandates as fundamental to building trust across the supply chain. “FSMA 204 is really about transparency. It’s saying, ‘Here’s a product, and we need to see a journey that we can trust,’” says Jackson.

Read more: How data is redefining the food supply

Regulators want high-risk products tracked at a granular level, but regulators aren’t the only ones with expectations. Both retailers and consumers are looking for greater insight into the journey of goods, and the companies that don’t deliver risk losing credibility, contracts, and consumer trust.

Jackson shares a story that highlights the real-world impact of traceability:

Consider what those seven days can mean in a recall: Potentially contaminated food remains on store shelves, legal liabilities grow, and public trust erodes. But with the right traceability system, that same process can take seconds—allowing businesses to swiftly isolate and remove affected products before they cause harm. 

Tosca’s Dr. Karin Witton chimes in, “Companies that ignore the regulatory and financial shifts happening right now are going to find themselves playing catch-up, while those that adapt early will be the ones setting the new standard.” 

Sunk costs aren’t viable anymore: The Extended Producer Responsibility factor

Traceability is only one part of the conversation, though. Today, the how of getting a product through the supply chain is also up for discussion.

We’re talking about packaging, of course. 

Businesses have long viewed packaging as a sunk cost—necessary, but disposable. But that way of thinking is at odds with new Extended Producer Requirement (EPR) laws. 

Tim Debus, President & CEO of the Reusable Packaging Association, explains why:

That means businesses have to assume the burden of packaging costs—and this isn’t a slow-moving issue. It’s happening now. 

But while single-use packaging is becoming a financial liability, companies that invest in reusable packaging will benefit from long-term cost savings and operational improvements.

Reusables aren’t a cost—they’re a cost saver

For companies looking to meet regulations and lower cost, reusable packaging is a strong investment. 

And unlike disposable packaging, reusables like Tosca’s product line operate in a pooling system, eliminating waste as logistics are improved.

Tosca’s Karin Witton shares: “What we do is use reusables all the way through to replacing single-use packaging, and at the end of life, our assets go for recycling to create new ones.” 

That leads to outcomes like: 

• 50% reduction in food waste by minimizing product damage and spoilage with durable, ventilated containers 
• 86% less solid waste compared to single-use packaging systems, reducing landfill contributions  
• 66% reduction in CO₂ emissions through optimized cube utilization and fewer transportation legs

Sustainability is an especially important business consideration; investing in reusable packaging gives businesses an edge as sustainability regulations expands.  

“We’ve talked for many years in the sustainability community about emission reduction, but that becomes more tangible when you start talking about how much packaging you’re buying, how it’s being moved around, how it’s being disposed of, and what you’re paying—not just in waste costs, but in regulatory fees.” – Dr.Karin Witton

The future of the food industry is circular, not linear

Traceability and sustainability are no longer separate discussions—they are two sides of the same issue. 

Businesses that embrace real-time tracking and reusable packaging will gain a competitive advantage by:

• Prioritize regulatory compliance with investments in end-to-end traceability and data accessibility
• Lower operational costs through efficient, reusable packaging systems that reduce waste and shrink
• Strengthen retail partnerships by meeting sustainability and traceability expectations
• Reinforce consumer trust with transparent tracking and responsible packaging choices

Those that delay the transition risk:

• Higher EPR fees and penalties as single-use packaging becomes a financial liability
• Lost contracts with major retailers that are tightening sustainability requirements
• Inefficient recalls and supply chain disruptions that damage brand reputation and financial stability

The shift toward smart traceability and reusable packaging goes beyond industry trends—it’s the new business model for an optimized, cost-efficient, and regulation-ready supply chain.

Partner with Tosca to future-proof your supply chain

Tosca’s reusable packaging solutions and IoT-enabled traceability technology give businesses the tools they need to stay ahead of regulatory changes while cutting costs and improving efficiency.

• Reduce costs with durable, reusable packaging that eliminates single-use waste and lowers per-unit spend
• Meet FSMA 204(d) traceability requirements with Tosca Asset IQ, providing real-time tracking and compliance-ready data
• Streamline sustainability efforts with a closed-loop system that eliminates waste and reduces carbon impact
• Enhance supply chain visibility to improve recall readiness and mitigate risk

The future of the food industry is circular, not linear. Businesses that embrace smart traceability and reusable packaging today will be the ones on the leading edge tomorrow.

Talk to a Tosca expert and future-proof your supply chain now.