"The New Era of Tech-Enabled Traceability": Tensions between the FDA's Data Governance Vision and the Lived Realities of Food Producers

2026-06-16

AI Summary

This study examines how the U.S. Food and Drug Administration’s new food traceability rule transforms small-scale agricultural producers into uncompensated data laborers, exacerbating existing burdens related to labor, financial resources, and technological capacity. Drawing on data feminist theory—an approach newly applied to food regulatory policy analysis—the research employs qualitative coding of 1,198 public comments to systematically uncover structural inequities embedded in the rule’s implementation. The analysis identifies three core tensions: the invisible burden of data labor imposed on marginalized actors, the technical infeasibility of mandated tracking systems for small operations, and regulatory ambiguity that fuels inconsistent enforcement. These findings offer both empirical evidence and theoretical innovation to inform the development of more inclusive and equitable data governance frameworks in food safety regulation.

Abstract

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.

Problem

• food traceability
• data governance
• regulatory burden
• agri-food stakeholders
• data labor

Innovation

• Data Feminism
• food traceability
• data labor
• regulatory burden
• agri-food governance