Live at GS1: Walmart, Brands Leverage Variable Label Data for FSMA 204

John Gibson, Director of Manufacturing Excellence at Conagra, described the scope of change for his team: “We have new conveyors and labeling equipment. I have to change every single print template for every SKU—both the each and the case”.

For packaging professionals, this means:

New Hardware Requirements

• Variable data printers that can handle serialized barcodes and lot-specific details
• Upgraded labelers capable of applying dynamic GS1-128 labels in real time
• Inline barcode scanners to validate label accuracy before a product moves to the next stage
• Integration with vision systems for label presence and correctness checks

Systems Integration

• Packaging lines must communicate with ERP or MES systems to retrieve KDEs (Key Data Elements) like lot number, production date, and source location.
• Dynamic printing logic must be implemented so that every label corresponds precisely to the product inside the case or on the pallet.

Change Management and Retraining

• Line operators must be retrained on variable data printing and exception handling,
• New SOPs are required for managing labeling exceptions or scan failures,
• Quality assurance teams must collaborate with packaging leads to ensure labels meet both regulatory and retail-specific requirements.

Case in Point: The Fishin’ Co. and Traceability from Pond to Pallet

Keith Flett, Sr. director of sustainability at The Fishin’ Co., explained how FSMA Rule 204 formalized what his team had already been pursuing for a decade under sustainability goals. “We’re able to track the soy that goes into our feed, that goes into our fish, that then goes to our processor, and on to the retailer,” he said.

Fishin’ Co. uses a process it calls CUPS—Collect, Upload, Push, and Store—to manage traceability data across global partners. But a major operational challenge came from getting data out of paper-based systems overseas and into digital formats that their ERP system could use for label generation.

His packaging team had to standardize data entry formats to ensure consistent printing logic, retrofit equipment at contract manufacturers overseas with new labelers and scanners, and use EPCIS protocols where applicable to maintain compatibility across partners.

Traceability as a Business Enabler

For both panelists being interviewed by Walmart's Bonin, traceability was more than a mandate—it was a performance tool.

Produce and other fresh foods are considered high risk, per FSMA Rule 204.Walmart Media Library

“We’re targeting waste reduction and tighter inventory control,” said Gibson. “We can focus our improvement efforts, prevent quality issues before they happen, and reduce near-misses. That only works with reliable traceability data—and that starts on the packaging line”.

Flett echoed this (they joked that there was a lot of parroting of comments going on): “We found small operational gaps where value was being lost. Traceability gives us a new lens—not just for compliance, but for better business decisions.”

Don’t Wait: Advice for Data and Packaging Teams Getting Started

The panelists were unanimous in their urgency:

• “Get started now.” Waiting for the final deadline is a mistake. “Retailer expectations haven’t changed,” said Flett. “Only the regulatory deadline has.”
• “Pick something and go.” You have to start somewhere, so as daunting as the entire task can appear, you have to begin eating any elephant with a first bite. Gibson recommended starting with ASN readiness: “It’s one of the biggest linchpins.”
• “Collaborate openly.” Walmart, Target, and other retailers are working toward consistent standards. “That’s a relief for us,” Gibson said. “What we fear most is everyone asking for something different.” He said brand owners should act the same, sharing as much in available pre-competitive environments, such as GS1 Connect events, as possible.

Bonin summed it up: “Let’s meet suppliers where they are, and work together toward a standardized solution.”

Packaging as a Traceability Engine

The packaging line has become a critical link in the food safety chain. For packaging professionals, FSMA Rule 204 means new responsibilities—but also new relevance.

Your labels are no longer static. They are dynamic carriers of compliance, efficiency, and brand trust. Every barcode must trace a product’s journey from raw material to retail shelf. Every printer, scanner, and applicator must operate as part of a larger data ecosystem. Every packaging operator becomes a custodian of transparency.

In the FSMA era, packaging isn’t just the last step before the truck leaves the dock. It’s the first line of defense in ensuring safety, earning consumer trust, and keeping retail relationships strong--especially ones with the world's 800-lb. retail gorilla.