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EU buyer requirement: Traceability of food

In brief

Presently traceability in the food sector is a key issue in international business. Due to the combination of several food product recalls and a complicated trading structures with more partners involved and spread through several countries, control of the whole supply chain has been extremely challenging. In cases of faulty products on the EU market, it proved to be often difficult for the responsible EU traders to trace all partners in the trading chain. Consequently the EU legislators have set traceability requirements for all parties within the EU.

Reacting on this obligation, the EU private sector developed additional traceability requirements as a risk-management tool within their supply chain management which will make it possible to withdraw or recall a product and trace back its origin at all times. For suppliers in developing countries the impact of traceability is merely an administrative issue; record keeping is the central activity. The more precise a company knows which product or ingredient caused the problem, where this product or ingredient came from and in what batch of final products this product or ingredient was used, the smaller the amount of products he will have to withdraw from the market. Internationally applied management systems such as GLOBALGAP, BRC, IFS and SQF 2000 include requirements on traceability.


From the point of view of a supplier in a developing country, it is important to 1) know, 2) document and 3) label the information required for implementing a traceability system.

1) Documentation from whom you have bought your products i.e. food

            - Document all inputs of raw materials and ingredients used in product (including origin)

     - Keep clear records of all products that are used in the production process

     - For primary producers, this requirement refers to seeds, bulbs, etc


2a) Documentation on products (ingredients) used during your production process

- Keep record which products, i.e. ingredients are mixed or processed to the final product during your production process.

- Records should be kept per batch of products. In case there is a problem with one set of products, it can be easily identified which steps are made within the production process and which batch contains faulty products.

- For primary production, it includes use of pesticides or other products used on the crop.

       - Keep clear records of all products that are used in the production process.


2b) Documentation to whom you supply your products


This information should be kept per batch of product so that, in case there is a problem with one set of products, it can be identified which client(s) should be notified.


3) Label the final products

The importer in the EU will most likely use a global information system that allows him to keep track of all products he imports to sell in the EU. The producers in developing countries, can keep track of their products by documenting the products that leave their premises, so that each batch can be clearly identified.

Traceability systems

Companies must have tracking and tracing procedures and systems. Only then, it is possible to have always data available upon demand by the enforcing authorities or EU buyers. Each tracing system requires the following information:

 - the identification and recording of inputs or finished products at company level and in relation to the supply chain

- the administration of data

- the communication of traceability data at company level or in relation to the supply chain  

- the supporting infrastructure in the chain for the recording and exchanging of data within a

network and the standard used


A wide range of traceability system is in use, e.g. EAN international and the Uniform Code Council standards (EAN/UCC standards), The Global Traceability Standard (GSP1). Within the framework of general traceability standards, food traceability standards or guidelines for specific food products have been developed. For instance, EAN/UCC introduced fresh produce, meat, fish and banana traceability guidelines. Traceability requirements are also included in commonly used food management systems such as GLOBALGAP, BRC, IFS and SQF 2000.

For more information, refer to the external links section where you can find links to EAN as well as an example of a banana traceability guideline.

Traceability in EU legislation

The traceability of food is legally binding requirement specified in the EU food legislation.

The Regulation (EC) 178/2002 (General Food Law) introduced traceability (Article 18) for all food and feed marketed in the EU. Traceability is compulsory for all food and feed businesses and requires all food operators implement supply chain management systems. Under EU law, traceability means the ability to track any food, feed, food-producing animal that will be used for consumption through all stages of production, processing and distribution.

Traceability in the EU follows the �one step back-one step forward� principle. Any business in the food chain, whether it is a farmer, food processor, transporters, importer, distributor or retailer, should be able to identify the immediate supplier of the product (one step back) and the immediate buyer (one step forward), with the exemption of retailers to final consumers.