Dairy manufacturers are used to complexity, from random weight products and liquid containers to temperature-sensitive logistics and tight retail relationships, but FSMA 204 compliance pressure has added a new layer that many operations are not yet ready for. The pressure isn't just operational anymore, it's regulatory, it's data-driven, and for a lot of companies, it's arriving faster than expected.
Chris Panneton, Senior Account Executive at TrueCommerce, and Kevin Head, Director of Food & Beverage at RSM, sat down recently to talk through what they're seeing in the industry. The conversation was candid and grounded in what's actually happening with dairy businesses right now. .
Retailers Aren't Waiting for the FDA
FSMA 204 has a compliance deadline that's been extended to mid-2028, but as Chris points out, that extension doesn't mean the work has been delayed.
"We're already in Q3 of 2026. It's coming. And we're starting to see those people really push to say, hey, I want to get those processes. I want to be ahead of the curve."
— Chris Panneton, Senior Account Executive, TrueCommerce
Kevin sees the same dynamic from the ERP side. Retail partners aren't waiting for federal enforcement to kick in. They're already asking their suppliers to send traceability data: that go well beyond a standard invoice or order acknowledgement.
"The deadline moved, but the work didn't go away. A lot of the big box retailers are saying, we know it's coming, so we're just going to start enforcing it anyways."
— Kevin Head, Director, Food & Beverage Industry, RSM
For dairy suppliers, that means the conversation is happening now. For those who aren't ready to send structured , it's becoming a business issue, not just an IT project.
The FSMA 204 Data Problem Is Not a Shortage. It Is Fragmentation.
One thing both Chris and Kevin agreed on immediately: most dairy companies have the data; the problem is where it lives.
"Most dairy companies don't struggle because they lack data. They struggle because their data exists in too many places."
— Kevin Head, Director, Food & Beverage Industry, RSM
When traceability events are scattered across a WMS, a production system, a spreadsheet, and an ERP, supply chain data integration becomes the missing piece. Without it, surfacing the right information quickly enough to satisfy retail requirements becomes a manual scramble. Kevin's team at RSM focuses on making the ERP the backbone, extending the data model to capture the events that are already happening in the system, and making that data easy to surface when it's needed.
Chris sees the impact of that fragmentation on the EDI side. Before a shipping document can go out the door electronically, the underlying data has to be organized, accurate, and accessible. If it isn't, EDI becomes a bottleneck instead of an advantage.
Tillamook Gets It Right
The conversation turned naturally to a mutual customer: Tillamook. Before moving to Microsoft Dynamics 365 Finance & Supply Chain Management (FSCM) with TrueCommerce's embedded EDI module, they were managing growth through manual effort. It was working, but not as well as they needed it to.
As Chris described it, the challenge wasn't unique to Tillamook. Dairy products don't conform neatly to standard EDI formats due to random weight blocks, liquid containers, variable case counts, etc. Managing that manually, across multiple retail partners with different requirements, creates a staffing problem as much as a technology one.
Kevin framed Tillamook's success clearly: the focus wasn't just compliance. It was operational efficiency that allowed them to then be compliant. By , they were able to scale without adding headcount for every new customer or channel.
Connected Supply Chain Operations Enable Growth
The last part of the conversation was less about compliance and more about what comes after. Both Chris and Kevin see dairy manufacturers looking beyond FSMA 204, toward and the higher order volumes that come with eCommerce growth.
"It's not just about having data anymore. It's about having data that you can make decisions off of. The companies that are in a position with connected systems are the ones that are going to see the most growth."
— Kevin Head, Director, Food & Beverage Industry, RSM
For manufacturers still running disconnected systems, that pivot is harder. Every new customer or channel requires manual setup, manual reconciliation, and manual risk. For those who've done the foundational work, growth becomes a process, not a project.
Listen to the Full Conversation
Hear Chris Panneton and Kevin Head cover FSMA 204 timelines, the Tillamook story, and what dairy manufacturers should be doing right now. .
Co-Authored with : RSM is a Solutions Partner for the Microsoft Cloud, helping food and beverage companies capture data and build real-time analytics across their entire global supply chain. RSM provides tailored Microsoft Dynamics 365 solutions designed to address the industry’s unique needs while fostering flexibility and growth.