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 Food Traceability Requirements

Traceability requirements were laid down at EC level by Regulation (EC) No. 178/2002, which requires traceability for food products, from the 1st January 2005.  

As a Regulation it is directly applicable in all EC Member States, including the UK .  

A copy of this Directive is available at:-

http://europa.eu.int/eur-lex/pri/en/oj/dat/2002/l_031/l_03120020201en00010024.pdf

In the UK , the General Food Regulations 2004 have been issued to provide for the enforcement of certain provisions of the above Regulation (EC) No. 178/2002.  

These Regulations do not reproduce the requirements of the EC Regulation but Guidance Notes have been issued to the General Food Regulations 2004:-:

http://www.food.gov.uk/multimedia/pdfs/generalfoodsafetyguide2.pdf

In accordance with Regulation (EC) No. 178/2002, the traceability of any food, feed, food-producing animal and any other substance intended for incorporation into a food or feed must be established at all stages of production, processing and distribution.  All operators must be able to identify who supplied a food, feed, food-producing animal or other substance, and the businesses to which they supplied their product(s).  

The traceability requirements apply to all stages of production processing and distribution, (i.e. a 'one up, one down' policy on traceability of foodstuffs and ingredients).

Essentially this means that you need to record:-

What you have received and from whom,

            When you received it,

What you did with it (e.g. which batches did a particular consignment of eg pepper go into),

Which customers or distributors you sell it to and when.

Lot marking requirements.

The Food (Lot Marking) Regulations 1996 require food products to be marked with a lot mark; however, a date mark may be used as a lot mark.

Certain foods are exempt from lot marking; these include foods which are in a package or container, of which the largest side has a surface area of les than 10 square centimetres. Examples of these would be salt/pepper/sugar/creamer powder/coffee sachets.  

The lot mark should be applied to the unit of sale.  Guidance notes to these Regulations have been published by the Food Standards Agency and give advice on bulk packaging.  These state that, a lot mark for items exempt, should be indicated on any outer container, for example it should appear on the outer catering pack which contains catering sachets.

The Food Standards Agency (FSA) have produced a Guidance Note:-

http://www.food.gov.uk/foodindustry/guidancenotes/labelregsguidance/foodlotmarkguid

Therefore, the individual sachets of salt/pepper/sugar/creamer powder/coffee etc. would not be required to be lot marked but, the carton in which they are packed (i.e. the unit of sale) would be required to be marked with a lot mark.

The coding of individual sachets is not required unless Nutshell, or their customers or distributors intend to ‘sell’ individual sachets, rather than supplying and using them ‘free of charge’ within the catering and food service sectors.

Ian Purse

 

 

Last updated 12 November 2008