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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
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