The FDA’s recent announcement delaying the FSMA 204 implementation deadline by 30 months has sparked a lot of conversation. Some see it as a reprieve. Others see it as a setback. What do I think?

I’m not concerned. Here’s why:

If the delayed deadline also means delayed traceability, of course that is a step backwards for food safety and public health. But from an implementation standpoint, I don’t believe we will lose momentum.

For large companies that have already begun building the infrastructure and processes to comply with FSMA 204 by the original January 2025 deadline, this delay doesn’t change much. These organizations have already budgeted for the expense, assigned internal teams, and built momentum. They’re not likely to stop just because the timeline moved. In fact, putting the work on pause now would be more disruptive and costly than simply finishing the job.

For these companies, completing FSMA 204 compliance is more than checking a regulatory box. Once they’re done, they’ll have an opportunity to frame it as a win with their customers. In an industry where we often hear the mantra “food safety is not a competitive advantage,” having traceability systems in place shows consumers and trading partners that they are taking the lead on transparency, technology, and readiness. That message is more powerful than a delayed deadline.

For companies that haven’t started or are still figuring out what FSMA 204 means for them, this delay will feel like a relief. It’s more time to sort out systems, budgets, and strategies. Some may use this as a reason to put off the work as long as they can.

Here’s the reality: that breathing room may be short-lived. Retailers, wholesalers, and foodservice customers are still going to expect progress. Many of them are moving forward with their own traceability requirements and timelines that don’t hinge on FDA enforcement dates. Just because the deadline moved doesn’t mean the pressure is off.

So, for companies who are already moving, stay the course. Stopping now won’t save you anything. For companies still in the early stages, take the extra time—but don’t waste it. The regulatory deadline may be delayed, but the business expectation hasn’t changed.

Ultimately, the companies that view FSMA 204 as an opportunity to improve how they operate—not just a rule they have to follow—will be in the strongest position. And that’s true with or without a deadline.