Traceability and legislation
The main requirements of Regulation (EC) 178/2002 are:
- Food (and feed) must not be unsafe, i.e. it must not be injurious to health or unfit for human consumption.
- Labelling, advertising and presentation of food must not mislead consumers.
- Food businesses must be able to identify the businesses from whom they have obtained food, ingredients or food producing animals and the businesses they have supplied with products, and produce this information on demand.
- Unsafe food must be withdrawn from sale or recalled from consumers if it has already been sold.
Traceability including product identity is an important and necessary part of meeting these requirements. It can aid in providing information on the composition of food products, the details for labelling, the source of raw materials, identity of business supplied with product, and the location of product in the supply chain including the market place.
Requirements of food businesses
Article 18 of Regulation (EC) 178/2002 covers the requirements for traceability. Under this article, food businesses are required to:
- identify their suppliers of food, food producing animals and other substances intended or expected to be incorporated into food,
- identify the businesses to which they have supplied products, and
- produce this information to the competent authorities on demand.
The purpose of the traceability provisions is to assist in targeted and accurate withdrawals and to give information to control authorities in the event of food safety problems, thereby avoiding the potential for wider disruption.
Commodity specific legislation
In addition to the requirements for traceability under Regulation 178/2002 and Article 18, which applies to all food businesses and food materials, traceability may be required by commodity specific legislation, for example products of animal origin (Regulation (EC) No 931/2011), genetically modified organisms (Regulation (EC) No 1830/2003) and seeds intended for sprouting (Regulation (EC) No 2008/2013).
However, it should be noted that the requirements for Country of Origin labelling (Regulation (EC) No 1337/2013) for meat of swine, sheep, goat and poultry are for the purpose of informing the consumer and for commercial interests rather than to achieve the traceability functions as set out in 178/2002.