External traceability and record keeping
The purpose of the traceability provisions in Regulation (EC) 178/2002 is to assist in targeted and accurate withdrawals and to give information to control authorities in the event of food safety problems. In essence this enables remedial action to be taken in a timely manner to protect the consumer.
The requirements apply to any business that trades in food at all stages of the food chain. This includes primary producers, those dealing with the purchase and sale of bulk commodities, processors/manufactures, wholesalers, transporters, distributors, food brokers, caterers and retailers.
Also included are businesses importing from third countries, even though their supplier is not within the EU.
Food producing animals and seeds
At the level of primary production and associated operations, live animals supplied for eventual use in food constitute ‘food producing animals’ and are subject to the traceability requirements. In addition, seeds will only be subject to the requirements if these go directly into food. Fertilisers, pesticides and veterinary medicines are not within the scope of the Regulation as they are not regarded as ‘food’.
Requirements around the final consumer
Food retailers are not required to identify the final consumer (since they are not food businesses). However, where a retailer knows it is supplying to another food business, e.g. a catering outlet, traceability requirements should be adhered to. Caterers such as restaurants, will need to keep records of inputs, but will not be required to keep records of supplies to the final consumer. Although forward traceability is not required for retailers, it is good practice for a food business to be able to demonstrate and have recorded how much product is sold to the final consumer, how much is waste and how much is wholesaled (if appropriate) – i.e. proper stock control as this information would be important for recall purposes, etc.
In summary, therefore all food business in the food supply chain, with certain exceptions at the primary production and retail level, within the EU 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 be able to make this information available within a reasonable time frame when requested.