Comment from Dot Foods, Inc.

As North America's largest less-than-truckload consolidator for the food industry, Dot Foods (“Dot”) supports the use of GS1 Standards as a practical and scalable means of implementing the Food Traceability Rule under FSMA Section 204. From a distributor's perspective, standardized master data, like GS1’s GTIN, is critical to identifying which products are subject to FSMA Rule 204 requirements. Dot plans to utilize GS1's product attributes, including attributes that identify Food Traceability List (FTL) items, to help determine which products are covered by the rule and require the collection and communication of traceability information. Adopting GS1 standards improves consistency between Dot and its trading partners and will facilitate rapid item set up while ensuring we know which new items require Key Data Elements (“KDEs”) to be received and passed forward. In addition, Dot relies heavily on GS1's established data exchange standards, including ASN 856 transactions and related GS1 data standards, to receive KDEs from suppliers and communicate to our customers. Dot’s ability to comply with FSMA 204 depends on the ability of supply chain participants to exchange information in a consistent manner, at scale, and in a way that does not restrict or impede product sales and flow (ie. placing product on hold for lack KDEs). While FSMA prohibits FDA from, "prescrib[ing] specific technologies for the maintenance of records", a system of standards is not a specific technology. Standards ensure consistency and interoperability throughout the supply chain, while technology enables the use of those standards and makes them usable at scale. Standards do not depend on any single technology. The same GS1 Standard can be applied across multiple technologies, and as technology evolves, the Standards remain constant. This consistency provides a common data language that can be shared throughout the supply chain, ensuring interoperability and supporting compliance with FSMA Rule 204. Dot Foods believes that broad adoption of GS1 Standards will help advance the objectives of FSMA Rule 204 by improving product identification, facilitating efficient data exchange, reducing implementation complexity, and enhancing the speed and accuracy of traceback activities. These benefits support both regulatory compliance and the broader goal of protecting public health through a safer and more transparent food supply chain.