Batch traceability

Traceability: batch identity from reception to dispatch

Traceability is a legal obligation before it is a service. This page sets out what EU law requires of a meat establishment, how batch identity is meant to carry through cutting, packing and dispatch, which identifiers EU rules require on the carton and on the shipping documents, and what a buyer can ask for.

What traceability means in law

Regulation (EC) 178/2002 makes traceability a condition of operating, not a commercial extra. Article 18 sets the traceability obligation itself; the marking and record-keeping duties described further down this page come from separate hygiene and labelling rules.

Six bone-in loin pieces arranged on a stainless steel table in a cutting room.

The chain, link by link

Each link is set out in turn: what it has to establish, and what carries batch identity to the next one.

  1. Incoming raw materialArticle 18 requires the supplier and the incoming material to be identifiable at reception. That record is the one-step-back link for everything produced from the material.
  2. Batch definitionGrouping production into batches is what gives a question about a single carton a bounded answer. How a batch is defined for a product belongs in the specification.
  3. Cutting and preparationCutting turns one incoming batch into several finished products. Reading that relationship in either direction afterwards depends on the records made at this point.
  4. Packing and markingMarking is the point at which batch identity becomes physically readable. What is printed on the carton is what a buyer quotes back when a question arises later.
  5. Cold storageStorage does not create a new batch. Product held chilled or frozen keeps the identity applied at marking, and that identity is what a later query is matched against.
  6. Consignment and documentsAt dispatch, the batches loaded together form one consignment, and it is the consignment that the commercial and official documents describe. The buyer's own records continue from there.

The identifiers EU rules require

These are the identifiers required on product of EU origin, and what each one identifies.

Product description and code
Ties the carton to the ordered specification. The catalogue's customs headings — 0203, 0206, 0209 and 0504 — are indicative; the subheading that applies depends on the goods shipped and on the destination tariff.
Batch or lot identifier
The field every later record is searched on. Quote it exactly as printed.
Identification mark
Identifies the approved establishment that last handled the product. It does not identify the batch.
Date marking
Regulation (EU) 1169/2011 requires the date of freezing to be given on frozen meat labelled for the final consumer. What is marked on a bulk carton is a matter for the specification agreed for the destination.
Origin information
Implementing Regulation (EU) 1337/2013 sets the «Reared in» and «Slaughtered in» indications for meat labelled for the final consumer, and permits a single «Origin» indication only where the animal was born, reared and slaughtered in the same country. What a bulk carton must carry is confirmed per destination.
Packing list and health certificate
The packing list connects cartons to the consignment; shipments to third countries travel under the official certificate model the destination requires.

What a buyer can ask for

These are the requests a buyer can send, and the references to include with each one.

Records that have to support a withdrawal

Article 19 of Regulation (EC) 178/2002 obliges an operator that has reason to believe food it placed on the market does not comply with the food safety requirements to withdraw it and inform the competent authority. Whether that can be done in an orderly way depends on how the records were kept beforehand.

Defining the scope

The first question is which batches are affected and which are not. Well-bounded batches keep a withdrawal proportionate; loosely defined ones widen it.

Finding where it went

One-step-forward records establish which customers and consignments received the affected batches; the buyer's own records continue that list further down the chain.

Keeping the underlying records

Regulation (EC) 852/2004 requires HACCP documents and records to be kept and made available to the competent authority. They are what a withdrawal is reconstructed from.

Traceability questions buyers ask

Is a batch the same as a production date?
Not necessarily. A production date is one common way to bound a batch, but a batch is defined by the conditions treated as uniform: product, period and incoming material. Ask how it is defined for the products you buy.
Does traceability reach back to the farm?
Article 18 requires one step back and one step forward from each operator, not the whole chain. Information about the farm sits with operators upstream, and how much of it can travel with a consignment is a point to settle before contracting.
What does the oval mark on an EU meat carton tell me?
It identifies the approved establishment that last handled the product: country name or two-letter code, approval number and the abbreviation CE/EC, as Annex II, Section I of Regulation (EC) 853/2004 requires. It is not a batch reference and not a certification mark.
What do I need to send to have a consignment traced?
The lot identifier printed on the cartons, the product code, and the invoice, packing list or consignment reference. Those three match a request to a specific delivery; without the lot identifier a delivery generally cannot be matched.
Is Trichinella testing part of the batch record?
Commission Implementing Regulation (EU) 2015/1375 places Trichinella controls at slaughter, other than for domestic swine from holdings or compartments officially recognised as applying controlled housing conditions. Where testing is carried out, the result attaches to the carcases covered, not to a later cutting batch.

Traceability requirements for your contract

Send the products, the destination market and the records your own certification requires. Those are the points to settle before an order is placed.

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Traceability, documentation and destination requirements, with the product codes you are considering.

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Include the specification and the records your own customer requires.

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