The Perfect Order Needs to Include the Right Data

Key takeaways

• The Perfect Order must evolve to include “right data.” Building on Dr. Edward J. Marien’s original 8Rs of the Perfect Order, Norman Katz argues that regulatory complexity and digital supply chains now require a ninth right: delivering every order with accurate, compliant, and integrated data.

• FDA FSMA 204 raises the bar on food traceability. The Food Safety Modernization Act (FSMA) 204 rule mandates detailed lot-level traceability—including manufacturing and expiration dates—especially for products on the Food Traceability List (FTL), with enforcement extended to July 20, 2028, but retailers already demanding compliance.

• EDI 856 ASNs are central to regulatory data transmission. The EDI 856 Advance Ship Notice (ASN) is the primary transaction used to transmit FSMA-required traceability data from vendors to retailers and grocers, making electronic data accuracy mission-critical.

• Spreadsheets and manual entry are no longer sufficient. To reduce regulatory risk and vendor compliance penalties, food and beverage companies must integrate FSMA data into ERP systems and production platforms, eliminating manual data entry and improving supply chain execution.

In February 2025, Supply Chain Management Review published my Perfect Order article series.  This 12-part series with accompanying Explainer articles expanded upon an article written by Dr. Edward J. Marien 20 years earlier where he described the eight Customer’s Bill of Rights (8Rs) that accompany any order.  Dr. Marien’s 8Rs state that a customer as a right to:

1. The Right Product

2. In the Right Quantity

3. From the Right Source

4. To the Right Destination

5. In the Right Condition

6. At the Right Time

7. With the Right Documentation

8. At the Right Cost

It would not be an incorrect assumption that embedded within each of the named rights, and as part of all of the documentation as I expanded upon what that could encompass (e.g., electronic transactions, labels, tags, paperwork), the data has to be right. But perhaps a ninth right—“With the Right Data”—should be added if, for no other reason, as a reminder and to reinforce some of the regulatory and compliance requirements companies are encountering.

One example of this is the FDA (Food and Drug Administration) FSMA (Food Safety Modernization Act) 204 compliance requirement.  The initial deadline was January 20, 2026, but has been extended until July 20, 2028. However, I can tell you from experience that retailers and grocers are not waiting to collect this data from their vendors whose products are on the FTL (Food Traceability List); they want this data now. 

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The FSMA data is primarily focused on a product’s lot traceability, manufacturing date, and expiration date. The methodology for conveying this data is EDI (Electronic Data Interchange).  The transaction used to carry this data from the vendor to the retailer or grocer is the EDI856 ASN (Advance Ship Notice).   

If your food or beverage company has been keeping track of data and manufacturing and expiration dates in spreadsheets, those days are effectively over. Yes, that meets FDA requirements, but it falls short of supply chain necessities. This data needs to be integrated into your ERP (Enterprise Resource Planning) system and/or tied into your production management system so it can be integrated with your EDI system or platform. Manual data entry is too prone to error and too time-intensive to continue to rely on.

Integrating FSMA data into your operations is a project that needs to be planned. Not complying with this FDA mandate is likely a regulatory problem. Not complying with this supply chain vendor compliance requirement makes your company a disruptive vendor. As I’ve stated before: In a commoditized world, execution is the competitive edge. If your competitors are complying and your company isn’t, whose products are your retail and grocery customers likely to focus on purchasing? The ones that increase risk due to a lack of the right regulatory data, or the ones that decrease risk because the right data was included? 

Customers have a right to the right data. Make sure you uphold this—and all of—Dr. Marien’s customer rights in your supply chain execution.

FAQs

Q: What is the “right data” concept in the Perfect Order framework?

“Right data” extends the traditional 8Rs of the Perfect Order to emphasize accurate, traceable, and regulatory-compliant information, especially critical under FDA FSMA 204 and retail vendor compliance standards.

Q: What does FDA FSMA 204 require from food and beverage suppliers?

FSMA 204 requires enhanced traceability for products on the Food Traceability List (FTL), including lot codes, manufacturing dates, expiration dates, and electronic data transmission, typically through EDI 856 ASNs.

Q: Why is ERP and EDI integration necessary for compliance?

FSMA data must flow seamlessly from production systems into ERP platforms and EDI networks to ensure accuracy, reduce manual errors, and meet retailer and grocer vendor compliance requirements.

Q: What are the risks of not complying with FSMA 204 or vendor data requirements?

Non-compliance can result in regulatory penalties, supply chain disruption, rejected shipments, damaged retailer relationships, and lost shelf space to competitors who deliver the “right data” consistently.