DHL Supply Chain Urges Food & Beverage Producers to Close Cold Storage Gaps Ahead of FDA’s Food Traceability Rule

• Approximately 10% of U.S. cold storage warehouses were built in the last five years, constraining access to modern facilities with the infrastructure to meet FDA traceability requirements
• Many legacy warehouses lack digital capabilities needed to maintain traceability across critical tracking events 

As the U.S. Food & Drug Administration (FDA) moves toward enforcement of the Food Traceability Final Rule (FSMA Section 204(d)) beginning July 20, 2028, DHL Supply Chain is urging food and beverage producers to use the extended runway to strengthen traceability capabilities across their cold-chain operations.

With more than 78% of U.S. cold storage warehouses built before 2000, and approximately 10% of current inventory built in the last five years, many producers are dependent on legacy facilities that were not designed for today’s data traceability and high-volume operating demands. DHL is addressing this gap by continuing to invest in modern, temperature-controlled warehousing, and through its MOU with RLCold, a food and beverage real estate developer, is set to add more than five million square feet of advanced cold-chain warehouses across North America in 2026.

“As the FDA moves to strengthen food safety requirements, global food producers and consumer packaged goods companies are rethinking their networks,” said Dennis Lutwen, President, Consumer, DHL Supply Chain North America. “Producers are looking for integrated, purpose-built extensions of their production infrastructure that includes traceability, reduces handoffs, and improves data integrity, rather than relying on shared, outdated public warehousing,” he said.

Considered one of the most significant food safety regulatory updates in more than a decade, the Food Traceability Rule applies to entities that manufacture, process, pack, or hold foods on the FDA’s Food Traceability List (FTL). The rule requires entities to maintain records containing Key Data Elements (KDEs), such as lot codes, product descriptions, quantities, locations, and timestamps, associated with Critical Tracking Events (CTEs), including receiving, shipping, and transformation. It also requires companies to provide requested traceability information to the FDA within 24 hours (or another timeframe agreed by the FDA) during investigations and recalls, moving the industry away from slow, voluntary recalls to faster identification and response.

FSMA 204(d) Raises  the Bar on Legacy Cold Storage Facilities

Through its New Era of Smarter Food Safety, the FDA has outlined a vision for transparent food supply chains, leveraging tools such as data sharing, advanced monitoring, and improved end-to-end visibility to help prevent contamination and strengthen outbreak response. Additionally, it is raising the bar for food and beverage manufacturers, driving greater emphasis on technology-enabled food safety. Many legacy cold storage facilities were built for maximum storage density, lacking integrated warehouse management systems and optimized operations that capture, link, and retain important data for rapid on-demand retrieval. Within these buildings, operators continue to rely on manual processes that make it difficult to link inbound and outbound records, often slowing down data retrieval during investigations and recalls.

Beyond Regulatory Compliance

In addition to ensuring its facilities are compliance-ready, DHL is prioritizing automation integration and sustainability in its cold-chain designs. Modern temperature-controlled facilities are equipped with advanced refrigeration and control systems, improved building envelopes, and digital operating models that support consistent, data-driven execution, and improved energy performance.

Additionally, DHL’s advanced cold-chain facilities are engineered for automation and semi-automation from day one. High-clearance, high-density racking systems are designed for intelligent, space-efficient storage, unlike many legacy facilities that can have structural barriers to automation.

Future-proofing Cold Chain Infrastructure

Under its MOU with RLCold, DHL Supply Chain is expected to deliver turnkey food-grade cold storage facilities across North America in phases, with initial sites progressing through design and pre-development during 2026. These investments reflect DHL’s long-term focus on strengthening cold-chain resilience, helping\ customers close critical infrastructure gaps and modernize their networks for the future.