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

Abstract

The U.S. Food and Drug Administration (FDA)’s Food Traceability Rule, promulgated as part of the Food Safety Modernization Act (FSMA), 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. This work contributes to CSCW by providing an empirical account of how data-driven policy reconfigures stakeholders as data producers. We demonstrate that those reconfigured as data workers under data-driven governance must be recognized as meaningful policy partners rather than merely as actors subjected to compliance obligations. We further suggest that CSCW can play a critical role in uncovering their yet invisible burdens, supporting their capacity to voice concerns through participatory democratic mechanisms, and aiding their ability to “make-do” under imposed data works.