Knowledge
Traceability under EU 178/2002: what a wholesaler must know immediately when it matters
A supplier recalls a batch. Which customers received it? What the regulation requires, where the chain breaks in practice and how to rehearse the real thing.
· 2 min read
What the regulation requires
Article 18 of Regulation (EC) No 178/2002 requires every food business to be able to identify its suppliers and its business customers — one step back, one step forward. This information must be made available to the authorities on request.
Article 19 covers what happens when a food is not safe: the business must withdraw it from the market, inform the authorities and — if the product may already have reached consumers — recall it. The regulation does not prescribe any particular technology. It demands a result: the right answer, fast.
Where the chain breaks in practice
- At goods-in the article is booked, but not the batch. From then on the information exists only on the carton — until the carton is gone.
- Repacking or portioning creates a new unit that does not carry its origin along.
- At picking, the picker grabs any batch of the right article. The delivery note shows the article, not the batch.
- The answer exists, but spread across delivery notes, spreadsheets and the memory of a colleague who happens to be on holiday.
The three questions when it matters
When a supplier recalls a batch, the authorities and your own customers always ask the same questions.
- Did we receive this batch?
- When, how much, from which supplier, on which delivery note.
- Where is it now?
- How much is still in stock and in which location — so it can be blocked immediately.
- Who received it?
- Which customers, on which day, in what quantity. That is the list you need to inform your buyers.
Rehearse the real thing
A mock recall is simple: take any batch from the last month and try to answer the three questions. The stopwatch runs. Many businesses find that the first question takes minutes while the third takes a day.
The exercise is worth doing twice a year — and after every change in the process, such as a new storage area or a new route. Document the result and you also have the evidence ready for the next inspection.
How long does your answer take today?
In a trial we run a mock recall with your own data — before and after. You see how many minutes it takes, not how many days.