168 Requirements for traceability of products

Requirements for traceability of products

The law requires that each company should have systems to document which products have been purchased from the individual supplier and which customer has purchased the company’s finished products. This also includes raw materials and other input factors covered by the legislation, ref.

Product areas covered by guidelines for traceability, recall and withdrawal.

The policies include traceability for:

  • commodities, plants, animals or food stuff
  • materials and objects that are intended to encounter, or may affect, commodities or food stuff.

The guidelines are recommended for foods and non-food products, except for pharmaceuticals.

Areas not described in the guidelines

  • Internal tracking systems
  • Fodder, allergic practices and agricultural practices, including the use of GMOs
  • Prevention of pollution (e.g. disinfectants)
  • Development and implementation of quality assurance in a company
  • Implementation of product and / or pallet labelling systems, etc.

The above areas are not described in the guidelines, but do not mean that there are no provisions or regulations for this elsewhere.

There is no requirement in the legislation for the types of systems to be used for this.
Traceability can be manually based in the simplest form, while others have an advanced IT system to follow up on this.

Central to the legislation is the duty of each company to undertake risk analysis over which health risks the products represent, and how the company will relate to this in terms of traceability.

Businesses can practice more comprehensive traceability systems than the minimum requirements of the law, but this is either based on self-imposed claims or agreements with, and orders from, the contracting parties.

Traceability is based on following the physical commodity flow.
All parties should be able to track their products one step forward and one backwards.

Traceability one step forward:
Traceability one step forward means the address to which the products are delivered to.
An invoice system that contains information about item number / tradename, customer number / customer name and invoice date is sufficient to track a step forward in the value chain.

If your business has one batch concept, this should be included in the invoice, Despatch Advice or that the company’s own expedition system is directly linked to the invoice.

Traceability one step backwards:
Traceability one step backwards means the address the products are delivered from.
The company must provide a log of received products describing which products are purchased from whom and in what quantity on date.

If the addresses for where products are delivered from or delivered to are not in accordance with the legal ownership of the products and the invoice fee, this should be agreed separately between the parties.

Published on: 9. August 2018