> ## Content Index > Fetch the complete content index at: https://tag-verify.ghost.io/llms.txt > Use this file to discover other available public pages before exploring further. # GS1-128 Labels for Leafy Greens: FSMA Rule 204 Requirements for 2026 and Beyond - URL: https://tag-verify.ghost.io/gs1-128-labels-leafy-greens-fsma-rule-204/ - Published: 2026-09-06T11:11:47.000Z - Updated: 2026-09-06T11:11:47.000Z - Author: Tag Verify Team Leafy greens — romaine lettuce, iceberg lettuce, spinach, arugula, spring mix, and similar commodities — are classified as high-risk foods under FDA's Food Safety Modernization Act Rule 204\. This means every entity that grows, harvests, packs, or ships leafy greens must maintain and share specific traceability records. Failure to maintain these records — or to transmit them in the format trading partners require — is now a compliance violation with regulatory consequences, not just a chargeback. Your GS1-128 pallet label is the machine-readable carrier for most of this traceability data. Here is what FSMA Rule 204 requires and how it maps to your label fields. What FSMA Rule 204 Requires FSMA Rule 204 (the Food Traceability Rule) requires that entities handling foods on the FDA's Food Traceability List (FTL) maintain records of Key Data Elements (KDEs) at each Critical Tracking Event (CTE) in the supply chain. For leafy greens, the Critical Tracking Events are: harvesting, cooling, initial packing, shipping, and receiving. At each CTE, specific Key Data Elements must be recorded and available to the FDA within 24 hours of a request. The Key Data Elements most directly captured on a GS1-128 pallet label: Traceability Lot Code (TLC): The identifier assigned to a specific harvest lot. This maps to Application Identifier (10) — the Lot or Batch Number on your GS1-128 label. The TLC must be specific enough to trace back to a single field, a single harvest date, and a single harvest crew. A generic lot code like "SEPT2026" does not meet the standard. Quantity: The number of cases or units on the pallet — AI (30) Count. Unit of Measure: The pack configuration (cases, pounds, bags). Location of the immediate previous source: Where this product came from — the grower, the ranch, the cooling facility. Your GS1 Global Location Number (GLN) serves this function. The GLN is a 13-digit number assigned by GS1 to uniquely identify a physical location. Location of the immediate subsequent recipient: Where this pallet is going — encoded in the Ship-To information on the human-readable zone and in the ASN. What Must Change on Your Label if You Ship Leafy Greens If your current leafy greens labels use a generic lot number (weekly codes, generic batch IDs, "N/A"): you are out of compliance with FSMA Rule 204 as of 2026\. The lot number on your label must trace back to a specific harvest event. Retailers — particularly Kroger, Whole Foods, and Albertsons — are already auditing this. Your lot number structure should encode (at minimum): farm identifier, field or growing block, harvest date, harvest shift or crew. An example structure: FARM01-FIELD3-260901-AM. This can be decoded by a traceability system to identify the exact origin of a recalled lot. If your current labels don't include a GLN: you should obtain one from GS1 US and include it in your label data. Retailers and trading partners are increasingly requiring GLNs to be present in EDI transactions and label data. What Retailers Are Doing Right Now Retailers are not waiting for the full 2028 enforcement deadline. As of 2026, major retailers have begun requiring FSMA-compliant traceability data as a condition of vendor approval for leafy greens: Whole Foods/Amazon: Requires lot-level traceability from approved suppliers as a contract requirement. Kroger: Has begun auditing lot number traceability for high-risk produce categories. Costco: Requires specific lot number formats for leafy greens that support trace-back. Walmart: Piloting digital traceability for leafy greens through their suppliers. If you can't trace a lot number on your label back to a harvest event within 4 hours, you are behind where major retailers expect you to be. The Practical Impact on Your Label Process You don't need new software to comply — but you do need a label process that captures and encodes specific harvest-level data, not generic batch codes. Your workflow must connect the harvest record (field, date, grower) to the lot number that goes on the label. Tag Verify supports FSMA Rule 204-compliant lot number encoding for leafy greens. When you enter your shipment data — including the harvest lot details — the platform validates that the lot number meets current traceability requirements before generating the GS1-128 barcode for your Zebra printer. Generate a compliant leafy greens pallet label at [tagverifyapp.com](https://tagverifyapp.com/?ref=tag-verify.ghost.io) — no account required.