Food traceability

What traceability is

Traceability is defined as the ability to trace and follow a food, feed, food-producing animal or substance intended to be, or expected to be, incorporated into a food or feed, through all stages of production, processing and distribution Article 3 of Regulation (EC) No 178/2002. The operative duty is in Article 18 of Regulation (EC) 178/2002: the traceability of food, feed, food-producing animals and any other substance intended to be, or expected to be, incorporated into a food or feed is to be established at all stages Article 18(1) of Regulation (EC) No 178/2002. It is a cross-cutting duty that precedes and complements the hygiene requirements of Regulation (EC) 852/2004 Article 3 of Regulation (EC) No 852/2004.

The "one step back, one step forward" model

The heart of Article 18 is paragraph 2: operators must be able to identify any person from whom they have been supplied with a food, a feed, a food-producing animal, or any substance intended to be, or expected to be, incorporated into a food or feed; to that end they are to have in place systems and procedures allowing the information to be made available to the competent authorities on demand Article 18(2) of Regulation (EC) No 178/2002. Paragraph 3 completes the downstream picture: operators must have in place systems and procedures to identify the businesses to which their products have been supplied; this information too is made available to the authority on demand Article 18(3) of Regulation (EC) No 178/2002.

Hence the shorthand "one step back, one step forward": the FBO must know the immediate supplier (upstream) and the immediate business customer (downstream). As a rule the duty does not extend to identifying the final consumer: the "step forward" stops at the business customer, not the individual retail purchaser. Paragraph 4 adds an obligation of adequate labelling or identification to facilitate traceability Article 18(4) of Regulation (EC) No 178/2002.

Withdrawal and recall (Articles 19-20)

Traceability matters above all in an emergency. Article 19 governs the handling of non-compliant food: if an operator considers or has reason to believe that a food it has imported, produced, processed, manufactured or distributed is not in compliance with food safety requirements, it is to immediately initiate procedures to withdraw it and to inform the competent authorities Article 19(1) of Regulation (EC) No 178/2002. Where the product may have reached the consumer, the operator is to effectively and accurately inform consumers of the reason for the withdrawal and, if necessary, recall products already supplied where other measures are not sufficient to achieve a high level of health protection Article 19(1) of Regulation (EC) No 178/2002. The practical distinction is sharp: withdrawal concerns product still in the commercial chain; recall is the further stage, with communication to the public, where the product has (or may have) reached the consumer.

Retail and distribution operators that do not affect the packaging, labelling, safety or integrity of the food are to cooperate by withdrawing non-compliant products and passing on the information needed to trace them Article 19(2) of Regulation (EC) No 178/2002. Operators inform and collaborate with the competent authorities on action taken to prevent or reduce risks Article 19(3) of Regulation (EC) No 178/2002. A parallel regime applies to feed Article 20(1) of Regulation (EC) No 178/2002.

Traceability and food safety: the link with HACCP

Traceability is not a stand-alone formality: it integrates with self-checking. An effective HACCP system presupposes knowledge of suppliers (to assess incoming hazards) and the ability to isolate a suspect batch quickly. In practice, traceability documentation — transport documents, invoices, goods-in/goods-out records, batch numbers — feeds into the food safety management manual. Traceability is also a premise for allergen management: identifying the source of a contamination requires tracing the chain back. For the operator's general obligations see the FBO page and, for the Italian penalty framework, the Italy page.