Food traceability under Regulation 178/2002 and the mock recall

Article 18 of Regulation (EC) 178/2002 requires two things of every food business. To know from whom it received a raw material or food and to whom it supplied its product. And to be able to show this to the authorities when they ask [1]. The European Commission calls this the “one step back, one step forward” approach [2]. Whether your records really work, you verify with a mock recall: you pick one batch, start a stopwatch and trace it to the raw materials and to the customers.

The obligation has applied since January 1, 2005 [1]. Below is what exactly the regulation requires, what data to keep for a batch, how long to keep it, what to do when withdrawing a product and how to run a mock recall step by step.

What exactly does Article 18 of Regulation 178/2002 require?

Article 18 sets a goal, not a method [2]. Four obligations follow from it [1]:

1. One step back. You must be able to identify from whom you received a food, raw material or substance you add to food.
2. One step forward. You must be able to identify the businesses to which you supplied your products. You do not have to record final consumers [2].
3. System and procedure. You must have the data organized so that you can give them to the authorities on request.
4. Labeling. Food on the market must be labeled or identified so that it can be traced.

The regulation does not require a separate system or software. According to the European Commission’s guidance, what matters is providing the information, not the format in which you keep it. The records must, however, be organized so that you can provide them without undue delay [2]. And they must track the physical movement of goods, not just invoices. An invoice will not tell you that a pallet is sitting in an external warehouse [2].

Internal traceability, i.e. the link between raw material batches and finished product batches within the company, is not explicitly prescribed by the regulation. Sector-specific rules are the exception [2]. The Commission’s guidance points out, however, that without it you cannot recall in a targeted and precise way [2]. There is a hard reason, too: when part of a batch is unsafe, the whole batch is presumed unsafe until a detailed assessment shows otherwise [1]. The more precisely you know what came from which delivery, the less you have to withdraw.

For food of animal origin there are more rules. Implementing Regulation (EU) 931/2011 lists the consignment data you must have available for customers and, on request, for the authorities. They must be updated daily. The regulation has applied since July 1, 2012 and does not cover foods that contain both plant products and processed products of animal origin [3].

What data must you have for each batch?

Article 18 does not give a list of data. The Commission’s guidance recommends a minimum, and Regulation 931/2011 makes a similar list mandatory for food of animal origin [2][3].

Data	In general, EC guidance recommendation [2]	Food of animal origin, 931/2011 [3]
Supplier: name, address, what was supplied	yes	yes, also the owner if different
Customer: name, address, what was received	yes	yes, also the owner if different
Delivery date	yes, with several deliveries per day also the time	dispatch date
Quantity or volume	yes	yes
Accurate description of the food	–	yes
Batch (LOT) or lot number	optional, but “very helpful”	yes, reference to the lot, batch or consignment

If you hold IFS Food certification, the standard goes further. The traceability system must link product batches to batches of raw materials and of packaging that touches the food or carries mandatory information. It covers receiving, every production step, the use of rework and distribution [4]. The batch should be marked right at packing. When you label later, the goods need their own batch marking in the meantime, and the shelf life is determined by the original production batch [4]. This mainly concerns repacking and relabeling.

How long should you keep traceability records?

Article 18 does not set a minimum period. The company decides. But if you cannot produce the records, you are in breach [2]. The Commission’s guidance proposes these periods. They are a recommendation and have no formal legal force [2].

Product	Recommended period according to EC guidance [2]
General rule	5 years from the date of manufacture or delivery
Highly perishable, with a use-by date shorter than 3 months or without a date, intended directly for the consumer	6 months from the date of manufacture or delivery
With a best-before date	shelf life + 6 months
Without a shelf-life date, for example wine	5 years

For food of animal origin, the data must be available at least until it can reasonably be assumed that the food has been consumed [3]. A sector-specific regulation [2] or a contract with a customer may require longer periods.

What to do when you have to withdraw a product?

Withdrawals are governed by Article 19 [1]. When you believe a food is not safe and it has already left your immediate control, you must:

1. Immediately start withdrawing it from the market and inform the competent authorities [1].
2. Inform consumers if the product may have reached them. Accurately, effectively and including the reason for the withdrawal [1].
3. Recall the product from consumers if other measures are not sufficient. In practice this means asking customers to return the product to the store or destroy it [2].

The Commission’s guidance distinguishes two things. A withdrawal removes the product from the supply chain. A recall concerns products customers already have at home [2]. If the product is still under your immediate control, the notification obligation under Article 19(1) does not arise [2]. A distributor that does not change the packaging or label must, within the scope of its activities, initiate the withdrawal and pass on the information needed for tracing [1].

Inform the authorities immediately also when you believe that a food on the market may be harmful to health. Include the measures you have taken [1]. In the Czech Republic, state supervision of food is carried out by the Czech Agriculture and Food Inspection Authority (Státní zemědělská a potravinářská inspekce, SZPI), the State Veterinary Administration (Státní veterinární správa, SVS) and the public health protection authorities [5]. Find out which of them you would report a withdrawal to before you need it.

This is not legal advice. For a specific case, consult a lawyer specializing in food law or the competent supervisory authority.

What is a mock recall and how do you run one?

A mock recall is a practice withdrawal of a product. You trace one batch as if it were a real problem. Regulation 178/2002 does not explicitly require the exercise [1]. The IFS Food version 8 standard, mandatory for certified companies since January 1, 2024 [6], does require it [4]:

• test the traceability system including the mass balance at least once every 12 months and with every significant change,
• test on samples that reflect the complexity of the product range, in both directions,
• trace the finished product to the raw materials and to the customers within at most 4 hours, or faster if the customer requires it, and record the result and the time,
• test the entire recall procedure end to end, plan it within 12 months and carry it out within 15 months at the latest.

Even without certification, a mock recall is a simple way to find where your records fall short. Before the authorities or a customer ask.

1. Pick a batch. Not the easiest one. Take a product with several raw materials, with rework or with repacking.
2. Start the stopwatch. Write down the start time and who is tracing.
3. Take a step back. For the finished product batch, trace the batches of all raw materials and packaging, the suppliers and the date of receipt.
4. Take a step forward. Find out to whom and when the batch was shipped, and in what quantity. How much remains in stock and where it physically is.
5. Calculate the mass balance. Compare the received quantity of raw material with consumption in production, shipments, stock and waste. Explain the difference.
6. Try the opposite direction. Take one raw material delivery and trace all the product batches it ended up in.
7. Stop the stopwatch and record the result. How long it took, what was missing, where you got stuck and what you will change.
8. Test the entire recall procedure too. Who decides, whether the contacts for customers and the authorities are up to date, and whether you have the text of the consumer notice prepared.

Where does traceability get stuck in practice?

During a mock recall, it pays to check these points in particular:

• The batch is not recorded at receiving. If nobody records it at receiving, it is later traced from delivery notes and memory.
• Deliveries get mixed. One production lot is made from two raw material deliveries and nobody recorded which ones. Then you withdraw both.
• Invoice instead of goods movement. Accounting knows whom you invoiced. It does not know where the pallet physically is [2].
• Relabeling. A new label may carry a different best-before date than the original batch. IFS, however, requires shelf life according to the original production batch [4].
• Data in four places. Delivery notes in a binder, production in a notebook, shipping in Excel, invoices in the accounting program. Every piece of data exists, but you put it together by hand.
• Batches enabled too late in the accounting program. In POHODA, tracking numbers (batches) are kept only for stock items of the Card or Product type, and you cannot add them retroactively to earlier movements [7]. In ABRA Flexi, batch and expiry tracking is enabled on the price list item, and the batch is then recorded on the stock movement line [8]. Enable it before you need it.

How we do it

At our own packing facility in Kuřim, we keep batches in one register. From it we can trace the path back to the raw material delivery and forward to the customer – exactly the two paths a mock recall tests.

Sources

1. Regulation (EC) No 178/2002 of the European Parliament and of the Council (EUR-Lex, Czech version): Article 3(15), Article 14(6), Article 18, Article 19 and Article 65. https://eur-lex.europa.eu/legal-content/CS/TXT/HTML/?uri=CELEX:32002R0178
2. European Commission – Guidance on the implementation of Articles 11, 12, 14, 17, 18, 19 and 20 of Regulation (EC) No 178/2002 on general food law (endorsed January 26, 2010, no formal legal force). https://food.ec.europa.eu/system/files/2016-10/gfl_req_guidance_rev_8_en.pdf
3. Commission Implementing Regulation (EU) No 931/2011 on traceability requirements for food of animal origin (EUR-Lex, Czech version). https://eur-lex.europa.eu/legal-content/CS/TXT/HTML/?uri=CELEX:32011R0931
4. IFS Food version 8 (April 2023), requirements 4.18 Traceability and 5.9 Management of product recalls, product withdrawals and incidents. https://www.ifs-certification.com/images/ifs_documents/IFS_Food_v8_standard_EN.pdf
5. Act No. 110/1997 Coll., on Foodstuffs and Tobacco Products, Section 14(1) (version from July 1, 2025). https://www.zakonyprolidi.cz/cs/1997-110
6. Bureau Veritas – IFS Food version 8 has been published (April 2023): audits from October 1, 2023, mandatory from January 1, 2024. https://certification.bureauveritas.com/newsroom/ifs-food-version-8-has-been-published-april-2023
7. Stormware – POHODA, Evidenční čísla (tracking numbers). https://www.stormware.cz/prirucka-pohoda-online/sklady/evidencni_cisla/
8. ABRA Flexi – Batch and expiration date assignment and their subsequent display. https://podpora.flexibee.eu/en/articles/3422002-batch-and-expiration-date-assignment-and-their-subsequent-display

How long does it take you to trace your batch?

In a free 30-minute audit, we will go through where batches are recorded at your company at receiving, in production and at shipping, and where the trail breaks. We will also tell you when paper or a spreadsheet is enough. You can find how we automate batch traceability on the Batch traceability page. Shelf-life monitoring in the warehouse is described on the Batches and expiry page, and an overview for the sector is in automation for food manufacturers. We also apply labels with batch numbers in our packing division: labeling.