The Regulation does not specify how long traceability records should be kept, although this may be required by specific sector legislation. It is for the business to decide how long to keep their records. The business should, however, bear in mind the nature of the food, its product life, and the circumstances under which the business might be required to produce records.
The food businesses should maintain genuine records to demonstrate effective traceability. Records should be legible, retained in good condition and retrievable. Ideally records should be retained for a defined period with consideration given to legal or customer requirements and to the shelf life of the products. Good practice for a food business is to retain traceability records for shelf life of the product plus a defined period, e.g. twelve months.
Article 18 of regulation (EC) 178/2002 does not require internal (process) traceability, i.e. the matching up of all inputs to outputs. Nor is their any requirement for records to be kept identifying how batches are split or combined within a food production operation to create particular products or new batches of the same product. For example a flour miller would not be required to specify which batch of wheat received went into which lot of flour (bag or bulk tank). However, internal traceability may be required by commodity specific legislation, for example beef labelling.
Internal traceability may also be required by a private voluntary standard adopted by the food business. This is not a legal requirement; it is a business to business agreement. For example, the BRC Global Standard for Food Safety (Issue 6) requires that a company shall be able to trace all raw material product lots from their supplier through all stages of processing and despatch to their customer and visa versa. This identification shall be adequate to ensure traceability. In addition, the company is required to test the traceability system to ensure traceability can be determined from raw material to finished product and visa versa.