Critical Tracking Events (CTEs) Explained

What Are Critical Tracking Events?

Critical Tracking Events (CTEs) are specific activities in the supply chain where traceability information must be captured to effectively track food products. They represent key points where food is transformed or changes hands, creating potential traceability gaps if not properly documented.

Under the FDA’s Food Traceability Rule, businesses handling foods on the Food Traceability List (FTL) must maintain records of these events and their associated Key Data Elements (KDEs).

The Five Critical Tracking Events

The FDA identifies five primary Critical Tracking Events that require documentation:

1. Growing 🌱

When a food is grown or raised before initial packing

Applies to: Farms, ranches, aquaculture operations

Examples: Harvesting leafy greens, collecting shell eggs, catching fish

2. Initial Packing 📦

When a raw agricultural commodity is first packaged

Applies to: Farms, packing houses, fishing vessels

Examples: Placing tomatoes in boxes, bagging fresh peppers, packaging shellfish

3. Processing/Manufacturing 🏭

When a food is transformed or created from one or more ingredients

Applies to: Food processors, manufacturers

Examples: Creating yogurt from milk, producing nut butter, making fresh-cut produce

4. Shipping 🚚

When a food is arranged for transport from one location to another

Applies to: All entities in the supply chain that ship food

Examples: Distributor sending products to retailer, manufacturer shipping to distributor

5. Receiving 📥

When a food is accepted at a new location after transport

Applies to: All entities in the supply chain that receive food

Examples: Retailer accepting delivery, restaurant receiving ingredients

When CTEs Occur in Your Supply Chain

Different businesses will encounter different Critical Tracking Events based on their role in the supply chain:

For Farms

Growing (when harvesting)
Initial Packing (when first packaging products)
Shipping (when sending products to buyers)

For Processors/Manufacturers

Receiving (when accepting raw materials)
Processing/Manufacturing (when transforming ingredients)
Shipping (when sending finished products)

For Distributors

Receiving (when accepting products)
Shipping (when sending products to customers)

For Retailers/Restaurants

Receiving (when accepting deliveries)
May also have Processing if preparing foods on-site

Required Information for Each CTE

Each Critical Tracking Event requires specific Key Data Elements to be recorded:

For Growing Events

Location description
Traceability lot code
Commodity and variety
Date of harvest
Growing area coordinates or address

For Initial Packing Events

Location of packing
Traceability lot code assignment
Date of packing
Quantity and unit of measure
Reference to growing information

For Processing/Manufacturing Events

Location of processing
Traceability lot code assignment
Date of processing
Description of the food
Quantity and unit of measure
References to incoming ingredients and their lot codes

For Shipping Events

Location shipping from
Location shipping to
Date of shipping
Traceability lot code(s) being shipped
Quantity and unit of measure
Reference to transporter information

For Receiving Events

Location receiving at
Location received from
Date of receipt
Traceability lot code(s) received
Quantity and unit of measure

Documenting CTEs Effectively

To ensure compliance with FDA requirements, follow these best practices:

1. Standardize Your Documentation

Create consistent templates for each CTE
Use the same format for dates, lot codes, and product descriptions

2. Embrace No-Code Automation Solutions

Implement ready-to-use traceability platforms instead of custom development
Use barcode or QR code scanning to eliminate manual data entry errors
Choose solutions with built-in FDA compliance validation

3. Avoid the Custom Coding Trap

Custom-coded solutions often fail to adapt to regulatory changes
Development delays can put compliance deadlines at risk
Maintenance costs for custom code typically exceed expectations

4. Automate Data Collection at CTEs

Deploy IoT sensors and automated scanning stations at key points
Integrate scale systems and production equipment with traceability software
Eliminate paper-based processes that introduce human error

5. Train Staff on CTE Recognition

Ensure employees can identify when CTEs occur
Provide clear procedures for using automated systems
Focus training on exception handling rather than routine data entry

6. Establish Record Verification Processes

Use automated data validation to ensure completeness
Implement real-time alerts for missing or inconsistent data
Verify that lot codes are properly maintained throughout the chain

7. Conduct Mock Traceability Exercises

Test your ability to connect CTEs across your operations
Practice tracing products forward and backward through your supply chain
Measure response time improvements from automation

Common Challenges with CTEs

❓ What if multiple CTEs happen at the same location?

Each CTE still requires its own documentation, even if they occur at the same facility or on the same day.

❓ Do I need to record CTEs for non-FTL foods?

The FDA only requires enhanced records for foods on the Food Traceability List, but maintaining similar records for all products is a best practice.

❓ What if I don’t have all the information from my suppliers?

The rule requires you to maintain records of the information provided to you. You should request all required KDEs from your suppliers.

Need Help Implementing CTE Documentation?

Properly documenting Critical Tracking Events is essential for FDA compliance and effective traceability. Our team can help you develop systems and procedures tailored to your specific operations.

👉 Contact us today for a consultation or system assessment.