"The New Era of Tech-Enabled Traceability": Tensions between the FDA's Data Governance Vision and the Lived Realities of Food Producers
For policymakers and agri-food stakeholders, it highlights how data-driven regulations disproportionately burden smaller producers, challenging the feasibility of uniform implementation.
The paper analyzes tensions between the FDA's data governance vision for food traceability and the burdens on smaller, under-resourced food producers, identifying three key tensions from 1,198 public comments.
The U.S. Food and Drug Administration (FDA)'s Food Traceability Rule requires agri-food supply chain stakeholders (stakeholders)--including farmers, fishers, retail workers, and others--to maintain detailed tracking records beginning in January 2026. Through this Rule, the FDA envisions a "New Era of Tech-Enabled Traceability," in which standardized, harmonized tracking data serve as a foundational public health infrastructure, enabling more rapid identification and removal of potentially contaminated food and ultimately reducing the risk of foodborne illness. Despite this promising vision, we observe that the Rule reconfigures agri-food stakeholders into data laborers by mandating stringent data collection, formatting, and reporting requirements. In this paper, we examine the tensions and burdens that arise from such reconfiguration. Leveraging Data Feminism as an orientation to attend to how data-driven policy implementation disproportionately burdens smaller, under-resourced stakeholders who lack the infrastructural and financial capacity to comply, we analyze 1,198 public comments submitted to Regulations.gov in response to the proposed Rule. Our qualitative document analysis reveals three key tensions: (1) the individual labor, financial, and educational burdens stakeholders experience as they are reconfigured into data workers; (2) moments where data tracking becomes infeasible due to infrastructural limitations, cultural contexts, and situated production practices; and (3) instances where the Rule's intended flexibility instead introduces confusion and burden due to its ambiguity.