Critical Tracking Events (CTEs)

What are Critical Tracking Events?

Critical Tracking Events (CTEs) are defined as events recorded throughout the supply chain that are essential for achieving food traceability and supply chain visibility. CTEs are dependent on industry standards specific to product categories, growing and processing procedures. Examples of Critical Tracking Events include harvesting, cooling, initial packing (RAC), first land-based receiver, shipping, receiving and transformation. Minimum requirements set forth by regulatory bodies for the capture and storage of CTEs have been defined in the traceability recordkeeping rule under the Food Safety Modernization Act (FSMA) section 204. 

Further specifications for the types of information that must be captured can be dependent based on the type of CTE. The pieces of information, or attributes, required for each CTE are called Key Data Elements (KDEs). KDEs for food traceability events include data elements such as time, location, lot code, quantities or other units, business identification information and more.

CTE Definitions from FSMA Regulation

In November 2022 the FDA published requirements for food traceability recordkeeping requirements for foods on the Food Traceability List (FTL). Companies need to understand their roles in the supply chain and determine which CTEs apply to their business.  This includes:

• Harvesting
  Harvesting applies to farms and farm mixed-type facilities and means activities that are traditionally performed on farms for the purpose of removing raw agriculture commodities (RACs) from the place they are grown or raised and preparing them for use as food.
• Cooling
  Cooling means active temperature reduction of a raw agricultural commodity (RAC) using hydrocooling, icing (except icing of seafood), forced air cooling, vacuum cooling, or a similar process.
• Initial Packing
  Initial Packing means packing a raw agricultural commodity (RAC), other than a food obtained from a fishing vessel, for the first time.
• First Land-Based Receiver
  First Land-based Receiver is the person taking possession of a food for the first time on land directly from a fishing vessel.
• Shipping
  Shipping is an event in a food’s supply chain in which a food is arranged for transport (e.g., by truck or ship) from one location to another location. Shipping does not include the sale or shipment of a food directly to a consumer or the donation of surplus food. Shipping does include sending an intracompany shipment of food from one location at a particular street address of a firm to another location at a different street address of the firm.
• Receiving
  Receiving is an event in a food’s supply chain in which a food is received by someone other than a consumer after being transported (e.g., by truck or ship) from another location. Receiving includes receipt of an intracompany shipment of food from one location at a particular street address of a firm to another location of the firm at a different street address.  
• Transformation
  Transformation is an event in a food’s supply chain that involves manufacturing/processing or changing a food (e.g., by commingling, repacking, or relabeling) or its packaging or packing, when the output is a food on the Food Traceability List (FTL). Transformation does not include the initial packing of a food or activities preceding that event (e.g., harvesting, cooling).

Businesses handling foods on the FTL may need to capture and store KDEs during any instance of the above CTEs. View which KDEs may apply to you for each of the named CTEs here.