Article 18 of Regulation (EC) 178/2002 does not require internal traceability, i.e. the matching up of all inputs to outputs. Nor is there a requirement for records to be kept identifying how batches are split and combined within a business to create products or new batches. However, internal traceability may be required by commodity specific legislation, e.g. beef labelling.
For a food business operation to effectively demonstrate traceability it may be necessary to implement a degree of internal traceability that is matching of inputs in terms of supplied materials to outputs in respect of products supplied.
Internal traceability features the identification and tracing of what is made from what, when and how, the so called process traceability. There are several types of operation in a food business that should be considered in establishing traceability, namely transfer, joining or aggregation and splitting.
- Transfer is perhaps the most straightforward in that material or batches are transferred directly as a unit from one process step to another.
- Joining is where one process step combines several units or batches of materials, for example where different ingredients are added to a product. Records should identify the components added or joined together.
- Splitting is where a traceable unit or batch is split for use in different processes or products. For example where material is drawn from a bulk store to make different products or used in different production batches.
The key to a successful internal traceability system is the assigning of unique identification to specific batches. Maintaining separation of batches can be achieved in space or time, for example physical separation in separate units or specific production run times.
What constitutes a batch will depend on the nature of the product and production operation. The identity placed on a batch should be easily assigned and read, and convey sufficient information to link the batch to relevant records.