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CONTENTS

ACKNOWLEDGEMENTS

ABSTRACT

1INTRODUCTION

1.1GENERAL BACKGROUND

1.2PURPOSE AND SCOPE OF THIS DOCUMENT

1.3HOW DO I USE THE DOCUMENT?

1.4WHO CAN USE THIS DOCUMENT?

FIGURE 1: TYPICAL

TABLE 1 TYPICAL ROLES IN THE FOOD SUPPLY CHAIN

1.5KEY TRACEABILITY AND RECALL DEFINITIONS AND ELEMENTS

1.5.1Traceability Definition

1.5.2Business Identification

1.5.3Trade Item Identification

1.5.4Batch/Lot Numbers and Serial Numbers

1.5.5Product Labels

FIGURE 1: EXAMPLES OF LABELS IDENTIFYING A TRADE ITEM

1.5.6Record Keeping

FIGURE 2: TRACEABILITY ELEMENTS IN THE TRACEABILITY FLOW

1.6TRACEABILITY SYSTEM REQUIREMENTS

1.6.1Identification of Food Business Operator

1.6.2Identification and Labeling

1.6.3Record Keeping:

1.6.4Chain of Custody

1.6.5Recall and Withdrawal

1.7REFERENCES USED TO ELABORATE THIS GUIDANCE DOCUMENT

1.7.1Regulations References

1.7.2Traceability Standard References

1.7.3Best Manufacture Practices (BMP) Standards

1.7.4Traceability Guides and Reports

2IMPLEMENTATION GUIDELINE FOR GROWERS

2.1HOW TO IDENTIFY THE FARM

2.1.1What additional farm information is required?

2.2CAPTURING PRODUCTION INPUTS

2.2.1Information that must be recorded when buying or receiving, and retained

2.3IDENTIFICATION OF TRADE ITEMS AND GROWER INFORMATION

2.3.1Identification of batches/lots

2.3.2Minimum information that must appear on the Trade Item label

FIGURE 3: EXAMPLES OF A LABEL IDENTIFYING A TRADE ITEM

2.4TRACEABILITY INFORMATION TO BE RECORDED

FIGURE 4: EXAMPLE OF INFORMATION RECORDED IN A FARM BOOK

2.4.1Information that must be recorded when using agricultural inputs

2.4.2Information that must be recorded and retained when selling

FIGURE 5: EXAMPLE OF A SALES RECEIPT

2.5DATA RETENTION

2.6RECALL AND WITHDRAWAL

2.7BUSINESS SCENARIO FOR GROWERS

2.7.1Grower delivers bulk to pack house (supermarket)

3IMPLEMENTATION GUIDELINE FOR PACKERS / RE-PACKERS

3.1IDENTIFICATION OF THE ORGANIZATION

3.2CAPTURING PRODUCTION INPUTS

3.2.1Information that must be recorded when buying or receiving, and retained

3.3IDENTIFICATION OF TRADE ITEMS AND PACKER/RE-PACKER INFORMATION

3.3.1Identification of production batches/lots

3.3.2How to Identify Non POS Trade Items

FIGURE 6: EXAMPLE OF A LABEL IDENTIFYING A NON POS TRADE ITEM

3.3.3Identification of POS Trade Items

FIGURE 7: EXAMPLE OF A LABEL UNIQUELY IDENTIFYING A POS TRADE ITEM

3.4TRACEABILITY INFORMATION TO BE RECORDED

3.5DATA RETENTION

3.6RECALL AND WITHDRAWAL

3.6.1Recalls requested by Competent Authority

3.6.2Voluntary Recalls

3.7BUSINESS SCENARIOS FOR PACKERS/RE-PACKERS

3.7.1Scenario 1: Shed (Packinghouse) Packed Product (Fresh Produce)

3.7.2Scenario 2: Produce Processing/Packing at the Supermarket

FIGURE 8: EXAMPLE OF CONTROLLED PRODUCTS DISPLAYED IN BULK IN THE STORE

3.7.3Scenario 3: Processing/Packing Plant (Supermarket) repacks poultry received from suppliers

3.7.4Scenario 4: Processing/Packing at the Store (Supermarket)

4IMPLEMENTATION GUIDELINE FOR DISTRIBUTORS/TRADERS

4.1IDENTIFICATION OF THE ORGANIZATION

4.2CAPTURING INPUTS

4.3IDENTIFICATION OF TRADE ITEMS

4.3.1Identification of production batches/lots by a company

4.4IDENTIFICATION OF LOGISTIC UNITS

4.4.1Case and Logistic Unit Labels

FIGURE 9: EXAMPLES OF CASE LABELS IDENTIFYING A TRADED PRODUCT (NON POS AND POS)

FIGURE 10: EXAMPLE OF A LABEL IDENTIFYING A LOGISTIC UNIT

FIGURE 11: EXAMPLE OF A GS1-128 PALLET LABEL UNIQUELY IDENTIFYING A LOGISTIC UNIT

4.5TRACEABILITY INFORMATION TO BE RECORDED

4.6DATA RETENTION

4.7RECALL AND WITHDRAWAL

4.7.1Recalls requested by Competent Authority

4.7.2Voluntary Recalls

4.8BUSINESS SCENARIOS FOR DISTRIBUTORS/TRADERS

4.8.1Scenario 1: Distributor receives imported product from a grower/exporter

4.8.2Scenario 2: Distributor receives and re-distributes produce from packers /others distributors/traders (including cooperatives, brokers, auctions)

5MANUFACTURER / PROCESSORS

5.1IDENTIFICATION OF THE ORGANIZATION

5.2CAPTURING PRODUCTION INPUTS

5.2.1Ingredients and Packaging Material

5.2.2Raw material

5.2.3Live Animals

5.3IDENTIFICATION OF TRADE ITEMS AND MANUFACTURER/PROCESSOR INFORMATION

5.3.1Identification of production batches/lots

5.3.2Identification of Non POS Trade Items

FIGURE 12: EXAMPLE OF A LABEL IDENTIFYING A NON POS TRADE ITEM

5.3.3Identification of POS Trade Items

FIGURE 13: EXAMPLE OF A LABEL UNIQUELY IDENTIFYING A CONSUMER UNIT

5.4IDENTIFICATION OF CASES OR PACKS

5.4.1Cases and Packs Labels

FIGURE 14: EXAMPLE OF A LABEL IDENTIFYING A CASE OR PACK

FIGURE 15: EXAMPLE OF CASE LABEL IDENTIFYING A CASE OR PACK WITH AN ITF-14

5.5TRACEABILITY INFORMATION TO BE RECORDED

5.6DATA RETENTION

5.7RECALL AND WITHDRAWAL

5.7.1Recalls requested by the Competent Authority

5.7.2Voluntary Recalls

5.8BUSINESS SCENARIOS FOR MANUFACTURERS/PROCESSORS

5.8.1Scenario 1: Condiment Manufacturer using ingredients from suppliers and selling products to Retail

5.8.2Scenario 2: Nutmeg Processor using raw material from growers

5.8.3Scenario 3: Cocoa Processor using raw material from growers

5.8.4Scenario 4: Fish Processor using raw material from vessels

5.8.5Scenario 5: Poultry Processor using raw material from farms and sold locally

6IMPLEMENTATION GUIDELINE FOR RETAIL STORES

6.1UNIQUE IDENTIFICATION OF THE ORGANIZATION

6.2CAPTURING INPUTS

6.3IDENTIFICATION OF TRADE ITEMS

WHAT IS A GLOBAL TRADE ITEM NUMBER?

HOW IS A GTIN ASSIGNED TO THE TRADED ITEMS THAT MY COMPANY PRODUCES?

FIGURE 16: EXAMPLE OF A LABEL UNIQUELY IDENTIFYING A CONSUMER UNIT

6.4TRACEABILITY INFORMATION TO BE RECORDED

6.5DATA RETENTION

6.6RECALL AND WITHDRAWAL

6.6.1Recalls requested by the Competent Authority

6.6.2Voluntary Recalls

6.7BUSINESS SCENARIOS FOR RETAIL STORES

6.7.1Receiving produce / products at Retailer’s produce packing center

FIGURE 17: EXAMPLE OF CONTROLLED PRODUCTS DISPLAYED IN BULK IN THE STORE

7IMPLEMENTATION GUIDELINE FOR FOODSERVICE OPERATORS

7.1IDENTIFICATION OF THE ORGANIZATION

7.2CAPTURING INPUTS

7.3TRACEABILITY INFORMATION TO BE RECORDED

7.4DATA RETENTION

7.5RECALL AND WITHDRAWAL

7.5.1Recalls requested by the Competent Authority

7.5.2Voluntary Recalls

7.6BUSINESS SCENARIOS FOR FOODSERVICE OPERATORS / RETAIL STORES

7.6.1Scenario 1: Restaurant Chain receives manufactured product direct-to-store

7.6.2Scenario 2: Hotel restaurant receives fresh produce product direct-to-store

8GLOSSARY

9APPENDIX 1: GLOBAL TRADE ITEM NUMBER (GTIN)

9.1GTIN ASSIGNMENT FURTHER EXPLAINED

WHY IS THE GTIN USEFUL?

9.1.1How to Create a Quality GS1-Compliant Bar Code

USE OF APPLICATION IDENTIFIERS (AIS):

FIGURE 18: USE OF APPLICATION IDENTIFIERS THROUGH THE PRODUCE SUPPLY CHAIN

TEN STEPS TO BAR CODE IMPLEMENTATION:

STEP 1: OBTAIN A COMPANY PREFIX

STEP 2: ASSIGN NUMBERS

STEP 3: SELECT A BAR CODE PRINTING COMPANY

STEP 4: SELECT A “PRIMARY” SCANNING ENVIRONMENT

STEP 5: SELECT A BAR CODE

STEP 6: PICK A BAR CODE SIZE

STEP 7: FORMAT THE BAR CODE TEXT

STEP 8: PICK A BAR CODE COLOUR

STEP 9: Pick the Bar Code Placement

9.2OTHER USEFUL RESOURCES

10APPENDIX 2: TRACEABILITY FORMS

10.1GROWERS FORMS

10.1.1Growers: Sales Receipt - Receiving

10.1.2Growers: Input Control Form

10.1.3Growers: Sales Receipt – Dispatch

10.1.4Growers: Farm Book Form

10.2PACKINGHOUSE/RE-PACKER FORMS

10.2.1Packinghouse/Re-Packer: Processing / Packing Form

10.2.2Packinghouse/Re-Packer: Input Control Form

10.2.3Packinghouse/Re-Packer: Sales Receipt – Dispatch

10.3POULTRY PROCESSING/PACKING PLANT FORMS

10.3.1Poultry Processing/Packing Plant - Input Control Form

10.3.2Poultry Processing/Packing Plant - Processing_Packing Form

10.3.3Poultry Processing/Packing Plant: Poultry - Shipment Receipt

10.4CONDIMENT MANUFACTURER FORMS

10.4.1Condiment Manufacturer - Sales Receipt Receiving

10.4.2Condiment Manufacturer - Input Control Form

10.4.3Condiment Manufacturer - Sales Receipt Dispatch

10.4.4Condiment Manufacturer - Manufacturing Process Form

10.5NUTMEG PROCESSOR FORMS

10.5.1Nutmeg Processor: Sales Receipt – Receiving

10.5.2Nutmeg Processor: Sales Receipt – Dispatch

10.5.3Nutmeg Processor: Control Summary Form

10.5.4Nutmeg Processor: Drying Process Form

10.5.5Nutmeg Processor: Packing Process Form

10.5.6Nutmeg Processor: Sales Receipt – Dispatch

10.6COCOA PROCESSOR FORMS

10.6.1Cocoa Processor: Sales Receipt - Receiving

10.6.2Cocoa Processor: Sales Receipt – Dispatch

10.6.3Cocoa Processor: Receiving Form

10.6.4Cocoa Processor: Drying/Packing Process Form

10.7FISH PROCESSOR FORMS

10.7.1Fish Processor: Sales Receipt – Receiving

10.7.2Fish Processor: Sales Receipt – Dispatch

10.7.3Fish Processor: Input Control Form

10.7.4Fish Processor: Packing Process Form

10.8POULTRY PROCESSOR FORMS

10.8.1Poultry Processor: Sales Receipt-Receiving

10.8.2Poultry Processor: Input Control Form

10.8.3Poultry Processor: Sales Receipt-Dispatch

10.8.4Poultry Processor: Packing Process Form

10.9SUPERMARKET – FRESH PRODUCE FORMS

10.9.1Supermarket – Fresh Produce Forms: Input Control Form

10.9.2Supermarket – Fresh Produce Forms: Processing / Packing Form

ACKNOWLEDGEMENTS

The Food and Agriculture Organization of the United Nations would like to express their appreciation to all those who contributed to the preparation and development of this publication.

Special appreciation is extended to Mr Juan Pablo Vial for his work on constructing this guide and conducting the pilots to assess feasibility in the value chains and countries.

Sincere thanks are also expressed to the project key focal points and their collaborators in the countries.

We thank the Inter-American Institute for Cooperation on Agriculture (IICA) for funding which enabled FAO to conduct pilots in the four countries where the project was implemented.

This publication was reviewed by Marisa Caipo, Ambra Gobena, Carmen Bullon, Cornelia Boesch and Vyjayanthi Lopez from FAO, as well as by Carol Thomas from IICA.

Special thanks go to Mr. Miguel Herrera for layout.

ABSTRACT

This document presents a set of criteria and traceability requirements to guide actors within the food industry to develop and implement a traceability system in selected food sectors that allows them to respond rapidly to food safety events.

The document was elaborated under the FAO project: TCP/SLC/3403 – “Strengthening capacity for a rapid response to food safety events through enhancement of the food traceability and recall legislation and systems in the Caribbean Sub region” and validated based on several pilots conducted within the EU-funded project implemented by IICA (‘SPS Project’): Support to the Forum of Caribbean States in the implementation of the commitments undertaken under the Economic Partnership Agreement (EPA): Sanitary and Phytosanitary (SPS) Measures”.

This document covers specific sectors that were identified in each of the four beneficiary countries for the provision of detailed guidance within the scope of TCP/SLC/3403 and the SPS Project. These are:

Antigua and Barbuda- fisheries, pineapple, carrot and onion sectors

Barbados- poultry, fisheries, and condiments sectors

Dominica- fresh produce, agro-processing and fisheries sectors

Grenada- nutmeg, cocoa, fisheries, and fresh produce sectors

This practical Guidance is intended for those responsible for implementing traceability in their organization’s operations and supply chain. The scope establishes both the minimum requirements and the best practices for the sharing of information along the supply chain. This guide covers:

Traceability practices from the supplier’s processing facility to the point of sale to the consumer;

All food products for human consumption;

All levels of the product hierarchy, including pallets, cases and consumer items; and

All supply chain segments including, suppliers, wholesalers, distributors, and retailers.

The minimum requirements presented in this Guidance are based on the assessment of the available national legislation or legislation that may support or influence food traceability and recall in each beneficiary country, the evaluation of the traceability situation on-site, the results of the pilots, the US and Europe traceability legislation, and the best practices recommended based on the information collected from several referenced documents.

After introductory chapters about general background, Traceability and Recall definitions, system requirements and references used, this document devotes several chapters to present detailed and specific implementation traceability and recall guidelines for growers, packers, exporters / importers, manufacturers, processors and distributors as well as their customers and suppliers with examples and business scenarios.

1    INTRODUCTION

Consumers expect safe and nutritious foods. They also expect all participants in the supply chain to have effective practices in place that allow for the rapid identification, location, and withdrawal of food lots when problems are suspected or confirmed. Ensuring that effective practices are in place across a complex and global supply chain is an on-going challenge. The increased focus on food safety and consumer awareness raises the need for the identification and adoption of business practices that will aid the ability of the trading partners in the food industry to track and trace a product throughout the supply chain.

1.1General background

The present document was elaborated under the FAO project: TCP/SLC/3403 – “Strengthening capacity for a rapid response to food safety events through enhancement of the food traceability and recall legislation and systems in the Caribbean Sub region”. The objective of this project was to assist the Governments of Antigua & Barbuda, Barbados, Dominica and Grenada in strengthening their capacities to respond rapidly to food safety events by enhancing the food traceability and recall legislation.

The project included an assessment of the available national legislation or legislation that may support or influence food traceability and recall, and a comprehensive mission to all four countries to meet with stakeholders and evaluate the traceability situation on-site.

The outputs achieved from the activities described above were used to set the criteria presented in this document to guide actors within the food industry of these countries to implement the principles and practices of traceability. The criteria were also used to draft text for food traceability and recall legislation, which could be included in the national food legislation.

Specific sectors were identified in each country in order to provide the detailed guidance that is contained within this document. These are:

Antigua and Barbuda- fisheries, pineapple, carrot and onion sectors

Barbados- poultry, fisheries, and condiments sectors

Dominica- fresh produce, agro-processing and fisheries sectors

Grenada- nutmeg, cocoa, fisheries, and fresh produce sectors

For each sector identified, different stages of the supply chain of the food sector were considered: food producer, food processor, importer of inputs to the product/s and food exporters.

The traceability requirements presented in this document were piloted and validated under the EU-funded project executed by IICA: Support to the Forum of Caribbean States in the implementation of the commitments undertaken under the Economic Partnership Agreement (EPA): Sanitary and Phytosanitary (SPS) Measures”, thus complementing the activities conducted earlier under the FAO project.

1.2Purpose and scope of this document

The food industry is comprised of a large array of trading partners, from the farmer or grower to internationally sourced suppliers. For this reason, this Traceability Guidance document has been developed to assist in the adoption of consistent business practices amongst all trading partners to effectively manage traceability for the food industry.

Supply chain inefficiencies in the food industry are driven from the lack of a national traceability regulation and the lack of adoption of global standards. This document is intended to provide all members of the food industry with guidance to develop and adopt business processes which provide traceability to a product within the entire supply chain, regardless of size or technological sophistication.

The scope of this Guidance document establishes both the minimum requirements and the best practices for the sharing of information between trading partners. This guide covers:

•Traceability practices from the supplier’s processing facility to the point of sale to the consumer;

•All food products for human consumption;

•All levels of the product hierarchy, including pallets, cases and consumer items; and

•All supply chain segments including, suppliers, wholesalers, distributors, and retailers.

Traceability is a business process that enables trading partners to follow products as they move from the field to retail store or food service operator. Each Traceability Partner must be able to identify the direct source (supplier) and direct recipient (customer) of the product. Traceability as a business process can be utilized for a variety of business purposes, including:

•Product Recalls/Market Withdrawals;

•Regulatory Compliance;

•Public Health Trace-backs;

•Food Safety and Quality Assurance; and

•Process and Order Management.

The first priority of traceability is to protect the consumer through faster and precise identification of a product under review. This is critical if the product is required to be withdrawn from the supply chain.

This document serves as guidance for implementing traceability in the food industry. The minimum requirements are based on the assessment of the available national legislation or legislation that may support or influence food traceability and recall in each country, the evaluation of the traceability situation on-site, the results of the pilots, the US and Europe traceability legislation and the best practices recommended based on the information collected from the referenced documents.

1.3How do I use the document?

Step 1:Read section 1.4 to determine your company’s role(s) in the supply chain.

Step 2:Read section 1.5 to understand key traceability definitions and principles.

Step 3:Read section 1.6 to understand the legal traceability requirements proposed.

Step 4:Review guidelines specific for your role(s) as outlined in sections 2 through 7.

Step 5:Begin implementation using the reference documents/appendices for assistance. Users should ensure that they fully understand specific government and/or industry requirements, or trading practices within the target markets they serve (e.g. document retention, origin/provenance, identification, e-commerce requirements).

1.4Who can use this document?

This practical Guidance is intended for those persons responsible for implementing traceability in the operations and supply chain of their organization. The document provides a guide for growers, packers, exporters/importers, manufacturers, processors and distributors as well as their customers and suppliers. Individual organizations may perform any combinations of these roles.

Table 1 describes the typical roles performed in supply chains.

1.5Key traceability and recall definitions and elements

1.5.1Traceability definition

Traceability is defined as the ability to discern, identify and follow the movement of a food or substance intended to be or expected to be incorporated into a food, through all stages of production, processing and distribution[1].

Product Recall is defined as the action to remove food from the market at any stage of the food chain, including that possessed by consumers. For the purposes of these Regulations, recall refers to food safety and food quality-based recalls[2].

1.5.2Business identification

Organizations (Companies or Persons) need to use a Food Business Identification number to identify the business they manage and then share that number with suppliers and customers.

The Food Business Identification number (BID) provides a uniform means of identifying a food business that is registered with the Competent Authority in a country. The BID is allocated by the Ministry of Agriculture, the Ministry of Health or any other designated government agency which maintains the National Business Registry for Food business operators.

Individual BIDs can be assigned to represent the organization as well as any individual trading subsidiaries.

1.5.3Trade item identification

A Trade Item is any product or service for which there is a need to retrieve pre-defined information and that may be priced, or ordered, or invoiced at any point in any supply chain.

Trade Item Identification is allocated by the creator of the product or service. The content, syntax, and format of the Trade Item Identification typically vary from one company to another, depending on company practice and the precision desired. For example, the Trade Item Identification may be the Commodity/Product name or the Commodity/Product name plus the BID, and/or a Product Code or GTIN[3] (If product goes to Retail POS).

1.5.4Batch/lot numbers and serial numbers

Lot or Batch Number means a reference number assigned by a food business operator to a series of similar goods, or goods produced under similar conditions. For crops, the lot number is the crop harvesting date, as decided when the crop/harvest starts. Lot and batch are defined/used synonymously and interchangeably.

All suppliers should assign Batch/Lot Numbers or Serial Numbers to case-level products they create. The content, syntax, and format of the batch or lot number itself typically varies from one company to another, depending on company practice and the precision desired. For example, a lot can represent all products produced in a day at one facility or the product produced in one hour from an individual packing line or it could represent a unique recipe run. In addition to the Batch/Lot Number, some suppliers also assign a unique Serial Number to each case and record the beginning and ending case Serial Numbers for each batch or lot.

It is important to remember that the range of products assigned to a single Batch/Lot Number also defines the minimum amount of product that may need to be removed from the supply chain in the event of a recall. This needs to be considered when defining your company’s standard practice for setting the scope of each Batch/Lot Number for each type of product that is produced.

Serial Numbers can be assigned to each case or pallet at the time of packing by the supplier. The format of the Serial Number may include a code representing the production facility and production date and time follow. Suppliers that use a case Serial Number for product tracking in place of a Batch/Lot Number must manage the Serial Number in a way that it affords a similar level of traceability as would be provided by a Batch/Lot Number.

1.5.5Product labels

Product labels are elements that physically identify traceable items, such as a tag, a sticker, or printing on product packaging that provides information about the product inside. Usually they are attached to the packing of every packed product but also can be printed or affixed. Normally product labels include the following information:

Business Identification Number (BID)

Product Identification or Description

Batch number

Additional information (best before date, harvesting date, weight, quantity, price)

Bar code (if required by customer)

1.5.6Record keeping

It is the act of creating a permanent piece of information constituting an account of something that has occurred. Normally, records are relevant traceability information that link final products (outputs) with ingredients, raw material and packaging material through their batch numbers. The information may be recorded using:

•Paper

•Pre-printed paper forms (examples in the last section of this document)

•Copybooks or Farm books

•Excel sheets

•Software (Management software, ERP, Traceability software)

The following diagram shows how an organization should link all the previous elements to build a traceability system.

Records should be maintained and readily available regarding the production and distribution of food, and food ingredients to facilitate prompt traceback to the immediate previous source and trace forward to the next subsequent recipients if a known or probable adverse effect on consumer health is identified. Also, they should be used for timely and effective withdrawal or recall of products if known or probable adverse effects on consumer health are identified.

1.6Traceability system requirements

Implementing a traceability system within a supply chain requires that all parties involved will link the physical flow of products with the flow of information about those products. Adopting regulations and industry standards for traceability processes ensures agreement about identification of the traceable items. This supports the visibility and continuity of information across the supply chain.

The following are the minimum requirements that should be implemented to build a Traceability System. All these requirements have been excerpted, without changes, from the document “Draft Food Traceability and Recall Legislation Recommendations”[4].

1.6.1Identification of food business operator

1.At the time of application for registration of the food business for domestic or imported food, in accordance with the Food Safety Act, the food business operator shall include the following information relevant to traceability, in addition to other application requirements as may be prescribed:

a)the name of the food business operator and contact information;

b)the business identification and registration details;

c)the name and contact details of the person responsible for traceability;

d)the address and telephone numbers of all locations registered under the business;

e)shelf- life or expiration date of the product;

f)conservation and storage methods for the product;

g)country of origin, in the case of imported food;

h)manufacturer or exporter company in the case of imported food;

i)the food business operator’s food traceability management plan.

2.At the time of registration, the Competent Authority shall assign the food business operator with a food business identification number (BID) that is used for the purposes of traceability.

3.Any food business operator, shall:

a)keep records for identifying any party that has supplied the food business operator, or to whom the food business operator supplies, a food or any substance intended to be incorporated into a food.

b)shall submit the identity and contact information of the traceability contact point for such food business to the Competent Authority upon request.

1.6.2Identification and labeling

1.6.2.1Identification

1.Food business operators must determine what needs to be traced. This is commonly referred to as the “traceable item.” A traceable item can be:

a)a packaged product or traded item (e.g. case/carton, consumer item)

b)a logistic unit (e.g. bin, container)

c)a shipment or movement of a product or trade item

There should be an agreement between trading partners on what the traceable item is. This ensures that both partners are tracking the same thing. Otherwise the chain is broken. Each trading partner should define at least one level of traceable item for each shipment.

2.A food business operator assigns an identification and batch or lot number to a specific range of traceable items and this is the smallest traceable unit that can be recalled. Where a food business operator uses a serial number in the package for product tracking in place of a batch or lot number, the food business operator must manage the serial number in such a way that it affords a similar level of traceability as would be provided by a batch/lot number.

3.When a product is reconfigured and/or re-packed, the new product must be assigned a new unique product identifier. A linkage should be maintained between the new product and its original inputs. A supplier and purchaser shall ensure the chain of custody of a traceable item and link the flow of a traceable item to the flow of information on such item, and record prescribed information on related business documents, including sales receipts.

1.6.2.2Labeling

1.All food business operators must systematically link the physical flow of products with the flow of information about those products. Traceable item identification should be communicated on related business documents and/or labels.

2.All traceable items must bear a label attached to the packaging with the following information in its most current, accurate and easily readable form:

a)food business identification number (BID) and the name of the brand owner;

b)description of the type of item by brand name (if applicable) and by specific variety (e.g. brand x cheddar cheese, not just cheese; romaine lettuce, not just lettuce);

c)product manufacturer, producer or processor;

d)batch/lot number;

e)code for date marking, as required by relevant legislation (e.g. best before, harvest, packing, manufactured or expiry); and

f)quantity.

3.A food business operator shall label food products at the time of packaging and shall temporarily label stored goods with a batch or lot number

4.Labels showing the traceable item identification number must remain on the packaging until the traceable item is consumed or destroyed (by the next trading partner). This principle applies even when the traceable item is part of a larger packaging hierarchy.

1.6.3Record keeping:

1.A food business operator shall collect and maintain the required traceable item information and a copy of the sales receipt for each incoming and outgoing transaction.

2.A sales receipt or other documentation involving the sale or transfer of a traceable item shall include the following information:

a)the name and contact information of the supplier, or the customer or trading partner, including food business identification number;

b)a description of the traceable item, including the brand name where applicable, and the specific variety or type of food;

c)the batch or lot number or other specific identifier of the traceable item, including the date of harvesting or the standard bar code for products destined for a retail customer;

d)quantity and packaging information;

e)price by unit or weight;

f)the date of the transaction;

g)address of origin from where the traceable item was delivered for incoming transactions or address of destination to where the traceable item will be delivered for outgoing transactions;

h)the name and contact information of the transporter; and

i)any other information deemed appropriate by the Competent Authority.

3.A food business operator shall keep records collected and maintained at a registered location or at another readily available location and shall make the records available to the Competent Authority within the time limit prescribed by the Competent Authority.

4.Records are maintained by the food business operator for a period of [twenty-four (24)] months after the expiration of the shelf-life of the traceable item.

1.6.4Chain of custody

1.A food business operator shall differentiate between Point of Sale[5] traceability items and non-Point of Sale traceability items for the purposes of recall and labelling.

2.A supplier and purchaser shall ensure the chain of custody of a traceable item and link the flow of a traceable item to the flow of information on such item, and record prescribed information on related business documents, including sales receipts.

3.The traceability system shall:

a)enable the identification of product through a Product ID, its Batch/lot number and their relation to identification and Batch/lot numbers of ingredients, raw materials and packaging in direct contact with food or packaging intended or expected to be in direct contact with food.

b)have the ability to trace back from the customer through all stages of processing to the supplier of ingredients, raw material and primary packaging materials, including transportation.

c)have the ability to trace forward from the suppliers of ingredients, raw material and primary packaging materials through all stages of processing to the customer, including transportation.

1.6.5Recall and withdrawal

1.6.5.1Recall strategy

1.A recall strategy should contain at least the following elements:

a)depth of recall, which may extend to the consumer level, the retail level, or the wholesale level;

b)the contents of public notifications to be issued depending on the classification and severity of the grounds for which a recall is issued;

c)during urgent situations, public warning that is given nationwide or to affected geographical areas;

d)effectiveness check level, which includes the method to be used for and depth recall effectiveness checks; and

e)the disposal of recalled products.

2.A recall strategy should take into account at least the following factors:

a)the health hazard evaluation;

b)the type or use of the product;

c)the ease in identifying the product;

d)the degree to which the product’s deficiency is obvious to the consumer or user;

e)the amount of product remaining unused in the marketplace;

f)the distribution pattern; and

g)the continued availability of essential products.

3.The recall strategy (see 1.6.5.1) would contain interim procedures to be put into effect in the period between the notification of a known or potential health hazard and a formal response to the hazard. The interim procedures would include the actions to be taken to ensure prompt warning regarding the extent of the recall. Warnings issued under this section shall identify the hazards involved and the steps to be taken to minimize exposure to the product hazard pending implementation of the full recall strategy.

1.6.5.2Recall classification system

1.The Competent Authority would be responsible for establishing a recall classification system, to be used in either a recall initiated by the food business operator or a recall initiated by the Competent Authority[6].

2.The recall classification system would specify the actions and timeframes to be undertaken depending on the type of non-compliance of the traceable item with these regulations. The recall classification system would establish fast-track procedures for food products that may pose risks to food safety.

3.The recall strategy would take into consideration the recall classification applicable to the situation.

1.6.5.3Recall initiated by a food business operator

1.Where a food business operator has reason to believe that a traceable item which has been imported, produced, processed, manufactured or distributed is not in compliance with the Act, he/she shall immediately take any of the following recall actions specifying the prescribed particulars of the traceable product to be recalled:

a)develop a recall strategy that meets the requirements in Section 1.6.5.1;

b)stop the distribution of the product;

c)withdraw the product from the market;

d)notify the public, trading partners and consignees of a recall as prescribed;

e)effectively and accurately inform the consumers of the reason for the recall and, if necessary, recall from consumers the products that have already supplied to them (when other measures are not sufficient to guarantee food safety) following the procedures established by the Competent Authority;

f)issue a press release if so directed by the Competent Authority; and

g)abide by other recall requirements as may be established by the Competent Authority.

2.The food business operator may request an informal discussion or hearing with the Competent Authority to discuss the recall actions to be taken, and shall provide the Competent Authority with the recall strategy and prescribed documentation.

1.6.5.4Recall initiated by the competent authority

1.The Competent Authority could develop a recall strategy in accordance with the requirements presented in the Recall Strategy (see 1.6.5.1).

2.Where the Competent Authority determines, based on information gathered, that there is a reasonable probability that a food is not in compliance with the Act or with relevant food standards and the use of or exposure to such food could cause adverse health consequences, the Competent Authority would:

a)provide a written recall order that includes a recall event number to the responsible food business operator, requiring a recall action to be taken within the period specified in the notice; or

b)where the food business operator does not comply with the recall order within the specified period and in the manner prescribed by the Competent Authority, or where the food business operator is unable to conduct a recall for any reason, initiate recall actions.

3.Where the time frame for carrying out a recall order allows, the Competent Authority would provide the food business operator subject to a recall order with an opportunity for an informal hearing, addressing the actions required by the order and the grounds for such action.

4.The Competent Authority, when necessary, would develop an interim recall strategy to cover the time between notification of a known or potential health hazard and completion of a final formal strategy. The interim recall strategy would indicate the immediate actions to be taken by the responsible food business operator.

5.The Competent Authority would notify appropriate local authorities of recall actions that may be pertinent to a specific district or area. Where the local authorities request assistance, the Competent Authority would respond and assist in conducting or auditing the recall action.

6.Where the Competent Authority determines, after providing opportunity for an informal hearing under subsection (4) of this section that the removal of the traceable item from the market is necessary, the Competent Authority would, either:

a)specify a timetable in which the recall shall occur, and shall amend the order to require recall of such traceable item or other appropriate action where required, and shall require periodic reports to the Competent Authority describing the progress of the recall and provide notice to consumers to whom such food product was, or may have been distributed; or

b)revoke the order, where the food business operator shows evidence that adequate grounds do not exist to continue the actions required by the recall order, or that the traceable item complies with the requirements of these Regulations.

7.The food business operator would bear the costs of a recall initiated by the Competent Authority and be responsible for disposal of a recalled product.

1.6.5.5Recall responsibilities and procedures involving an importer or exporter

1.Where an importer has reason to believe that a food item which he or she has imported is not in compliance with these Regulations, or receives a recall order from the Competent Authority, the food importer would:

a)adapt the strategy to the situation

b)immediately develop and implement a recall strategy based on the requirements of the Regulations, and, when appropriate, extend the recall to its consignees;

c)provide the consignees with information necessary to make it possible to locate the product in its distribution system;

d)inform the Competent Authority of where and how far into the supply chain the food has gone and whether any of the targeted product has reached consumers, and

e)notify the public, trading partners and consignees of a recall, as prescribed.

2.Where a recall order involves an imported food, the Competent Authority would inform the relevant food safety authority in the country of origin of the particulars involving the recall order.

3.For recall action involving exported food, the Competent Authority, at the request of the exporter or at its own initiative, would summarize and transmit essential information to the food safety authority in the importing country.

1.6.5.6Termination of recall order

1.The Competent Authority would terminate a recall order when the Competent Authority determines that the recall activity has been completed, or is satisfied that the food business operator has brought the food in compliance with the Act and its Regulations, or has disposed of the food in the prescribed manner where required.

2.Once the Competent Authority terminates the recall order, the Competent Authority would notify the affected food business operator by letter and email that the Competent Authority considers the recall order terminated.

1.7References used to elaborate this guidance document

1.7.1Regulations references

In the preparation of this guidance document, the following international regulations have been considered in order to ensure its fulfilment:

•Regulation (CE) N° 178/2002, “Laying down the general principles and requirements of food law, establishing the European Food Safety Authority and laying down procedures in matters of food safety” of the European Parliament and of the Council of January 28, 2002[7].

•Public Health Security and Bioterrorism Preparedness and Response Act of 2002, “To improve the ability of the United States to prevent, prepare for, and respond to bioterrorism and other public health emergencies”, United States Food and Drug Administration (FDA), June 12, 2002[8].

•Public Law 111–353 FDA Food Safety Modernization Act of 2011, “To amend the Federal Food, Drug, and Cosmetic Act with respect to the safety of the food supply”, United States Food and Drug Administration (FDA), January 4, 2011[9].

•Draft Food Traceability and Recall Legislation Recommendations, developed under a project funded by the Food and Agriculture Organization (FAO) - TCP/SLC/3403 – “Strengthening capacity for a rapid response to food safety events through enhancement of the food traceability and recall legislation and systems in the Caribbean Sub region”, 2014 – 2016.

1.7.2Traceability standard references

The following referenced traceability standards were used as base documents to draw up the requirements.

•GS1 Global Traceability Standard – Business Process and System Requirements for Full Chain Traceability (GS1 GTS)[10].

•ISO 22005:2007, Traceability in feed and food chain – General principles and basic requirements for system design and implementation[11].

1.7.3Best manufacture practices (bmp) standards

There are several recommended requirements in this document that fulfil the traceability requirements in the next main quality standards for the food supply chain.

•ISO 9001:2015[12]

•HACCP (ISO 22000:2005)[13]

•BRC (British Retail Consortium) Global Standard - Food[14]

•IFS (International Featured Standard) - Food[15]

•SQF (Safe Quality Food)[16]

•GlobalGap[17]

1.7.4Traceability guides and reports

The following list of documents was used as reference for the recommended requirements:

•Vincent, A. (2014, February). Review and Analysis of Current Traceability Practices. Rome: FAO Committee on Fisheries, Subcommittee of Fish Trade.

•FAO Committee on Fisheries; Subcommittee of Fish Trade. (2014, February). Best Practice Guidelines on Traceability. Rome: Author.

•Ryder, J., Karunasagar, I., Lahsen, A. (2014). Assessment and management of seafood safety and quality - Current practices and emerging issues. Rome: FAO Fisheries and Aquaculture Technical Paper.

•Huss, H.H., Ryder, J. (2014). Prerequisites to HACCP. Rome: FAO Fisheries and Aquaculture Technical Paper.

•FAO/WHO guide for developing and improving national food recall systems (http://www.fao.org/docrep/017/i3006e/i3006e.pdf)

•FAO/WHO guide for application of risk analysis principles and procedures during food safety emergencies (http://www.fao.org/docrep/014/ba0092e/ba0092e00.pdf)

2    IMPLEMENTATION GUIDELINE FOR GROWERS

This section is intended for Growers who are NOT packing the product (i.e. their only role is that of a primary producer). Growers who pack the product should also refer to Section 3.

Examples of Growers are: Produce Farmers

2.1How to identify the farm

Growers need to use the Business Identification (BID) to identify the farms they manage (also called Farm ID). The BID can be used to uniquely identify a single Farm and its premises. The BID is allocated by the Ministry of Agriculture or any other designated government agency which maintains the National Farm Registry.

2.1.1What additional farm information is required?

It is recommended to the Growers to identify all the plots in every farm they manage and if possible, all the crops in every plot. This shall give the opportunity to identify all the agricultural inputs used in every plot and crop.

If all the crops are mixed in one plot (thus impossible to differentiate them), then it is assumed that all inputs used for one crop are used for all the other crops in the same plot. In the same sense, if it is not possible to differentiate the plots in a Farm, then it is assumed that all the inputs used for one plot are used in the whole Farm.

2.2Capturing production inputs

To enable traceability, growers must maintain records of essential information related to the production of the product (e.g. agricultural inputs used, including date of application).

2.2.1Information that must be recorded when buying or receiving, and retained

Each time a grower buys or receives a product that may be applied to the crop it is required to retain a copy of the Sales Receipt given by the supplier. The Sales Receipt copy should at least include the following information:

•Supplier/Seller name

•Supplier/Seller contact information

•Supplier BID

•Customer name

•Customer BID

•Product Description (Brand name if applicable, including variety)

•Lot number or other batch identifier of the good

•Quantity and packaging information

•Purchasing or receiving date

•Address from where the good was purchased/delivered

•Name and contact information of the transporter

•Any other information deemed appropriate by the Competent Authority

It is recommended for growers to also include the following information:

•Sales Receipt number

•Product identification number (if available)

•Name and signature of person who received the product

•Name and signature of person who dispatched the product

It is important to highlight that it is the Grower’s decision to record this information also in a registry such as a Farm Book (See section 2.4).

2.3Identification of trade items and grower information

Each Trade Item destined for a subsequent trading partner (i.e. packing facility, retailer facility) must be identified. Examples of Trade Items include bags, cartons, bins, totes, containers, trailers (normally the container the Grower uses to transport the product).

To assist customers with their subsequent traceability, growers shall attach a tag/label to their Trade Items, in human-readable format (could be handwritten), with all relevant grower/harvest information. Products are labeled at the time of packaging or distribution.

2.3.1Identification of batches/lots

Growers must assign a batch/lot number to the products they harvest. The batch /lot number itself depends on the grower’s criteria. For example, a batch/lot number can represent a harvesting day and for a specific crop or may be the harvesting date for the entire farm. The batch/lot should be internally linked to the Farm/crop information and records (in a Farm Book – See Section 2.4).

2.3.2Minimum information that must appear on the Trade Item label

Each Trade Item shall provide at least the following data in human-readable format:

•Grower’s name

•BID (Farm BID)

•Commodity name and, where applicable, variety name

•Lot number (use of the harvesting date is recommended)

•Code for date marking, as required by relevant legislation

•Quantity

2.4Traceability information to be recorded

Growers shall record (on paper or in electronic form) the required information associated with each plot/crop in any farm (BID) that they manage. These records should be organized chronologically by dates.

Note: To record the traceability information, the use of a “Farm Book” is recommended. The “Farm Book” is a simple notebook (e.g. a copybook) wherein a grower records cultural practices, plant protection treatments and additional information that may be considered of importance in relation to crop management. This tool gives the growers control over their farm, providing a method to record chronological information about the production of any crop within a harvesting season.

2.4.1Information that must be recorded when using agricultural inputs

Each time a grower applies or uses a product (agricultural input) in a plot or crop, the following information is recorded.

•Farm Name

•Farm BID

•Plot identification (and crop identification if possible)

•Date of application

•Product Description (Brand name if applicable, including variety)

•Lot number or other batch identifier of the good

•Supplier BID

•Quantity applied

2.4.2Information that must be recorded and retained when selling

Each time a grower sells a Trade Item to a trading partner, the following data must be recorded in order to ensure that the traceability link is maintained. These represent the minimum data set required to ensure traceability between the grower and their trading partners.

•Supplier/Seller name

•Supplier/Seller contact information

•Supplier BID

•Customer name

•Customer BID

•Product Description (Brand name if applicable, including variety)

•Lot number or other batch identifier of the good (i.e. harvesting date)

•Quantity and packaging information

•Date of transaction

•Origin Address: Address from where the good was delivered

•Destination Address: Address of receiving location/trading partner

•Name and contact information of the transporter

•Any other information deemed appropriate by the Competent Authority

This information is recorded in a sales receipt or any other documentation involving the sale or transfer of a trade item.

It is recommended that growers also include the following information:

•Sales Receipt number

•Product identification number (if available)

•Price

•Name and signature of person who dispatched the product

•Name and signature of person who received the product

Definitions for data attributes are provided in the Glossary of Terms (see section 8).

It is important to highlight that the Grower needs to record the same information as the one that appears in the Sales Receipt. Thus, the decision to record this information in a registry such as the Farm Book is up to the Grower.

If the Grower does not have the means to provide a “Sales Receipt” to his/her customers, s/he can ask the customer to provide the “Sales Receipt” when receiving the products and then keep a copy of the Sales Receipt. In any case, both the Grower and the customer must retain a copy of the Sales Receipt. This requirement only applies when the customer is a Trading Partner (i.e. retailer, packer, exporter, distributor, hotel, and restaurant).

2.5Data retention

All companies are expected to maintain / retain records that will facilitate timely and accurate traceability and support any product recalls.

Records are retained at a registered location or at another readily available location and made available to the Competent Authority within the time limit prescribed by [rule/order] approved by the Competent Authority. In the absence of a prescribed time, the retention time should be the maximum time by which the produce is consumed plus a safety margin of six months.

2.6Recall and withdrawal

Since the growers do not have the resources to recall/withdraw, it is suggested that the responsibility for recall/withdrawal upstream be placed on the packers and re-packers. As mentioned in the previous section, they only need to have the records on site or at a readily available location in order to be retrieved “as soon as possible” after request by any partner or by the competent authorities on demand.

2.7Business scenario for growers

2.7.1Grower delivers bulk to pack house (supermarket)

2.7.1.1Description of the process

The farmer grows, harvests, and transports vegetables to the supermarket which, in turn, receives, sorts, grades and packs the vegetables received into the “finished product” configurations.

The process begins with the start of a cropping season or growing season. During this period, the farmer is responsible for recording and maintaining information for all the inputs used on the plot (seeds, chemicals, fertilizers, etc.). If the farmer plants mixed crops in the plot, then it is assumed that all the inputs are applied over all the crops in the plot.

Once the vegetables are ready for harvest, the farmer is responsible for recording information that will enable batch/lot assignment during the packing process. The farmer is also responsible for providing this information to the supermarket when the product is delivered.

All the vegetables that the farmer prepares to deliver to the supermarket should be labeled / tagged with the commodity name/description, product identification number (GTIN if applicable) and batch/lot number which is assigned.

2.7.1.2Description of the traceability process for farmers:

Receiving Inputs

When the farmer buys an agricultural input, he must keep and store the “Sales Receipt” (see Appendix 2 – Section 10.1.1) given by the input Supplier. The required traceability information in the Sales Receipt is the following:

-Supplier Name, Business Identification Number and Address

-Date

-Product Description

-Batch/lot number

-Quantity

-Farmer name, address and Business ID Number

Note: If the input Supplier doesn’t gives a Sales Receipt with all the required information, then the farmer must register the required information using the sample Input Control Form (see Appendix 2 – Section 10.1.2) and staple this together the sales receipt/invoice given by the input Supplier in order to complete the record of inputs.

Farming and Harvesting Process

Every day, the farmer records information related to the day’s activity based on the commodity and field being worked (i.e. Farm/Plot, Unit/Block) using a Farm Book (see Appendix 2 – Section 10.1.4). All agricultural inputs applied to each field are recorded. The information to record is as follows:

-Farm ID

-Campaign/Season

-Plot

-Crop (Commodity Name)

-Input to be applied

-Date of Application

-Lot number

-Quantity

At harvest, the farmer reaps the product and collects it in bags (or other convenient type of container: bin, carton, etc.). A human- readable “field tag” or label should be applied to the bags as they are filled (see image). The “field tag’’ or label generally should contain the following information:

-Farmer Name

-Farmer Business Identification Number

-Commodity Description

-Harvesting Date (dd/mm/yy)

-Quantity

Note: Farmers don’t need to assign a label when delivering if they transfer their products to the customer’s bins or containers when the customer receives. In this case it is the customer who is required to assign a label to each bin or container in order to control the origin of the received products.

Delivery Process

When the farmer delivers the product, the farmer must issue a sales receipt (one copy given to the supermarket, one copy retained by the farmer) (see Appendix 2 – Section 10.1.3). The information to record in the sales receipt is as follows:

-Farmer’s Name, Business Identification Number and Delivery Address

-Product Description

-Batch number or Harvesting Date (dd/mm/yy)

-Quantity

-Receiving facility name, address and Supermarket Business ID Number

3    IMPLEMENTATION GUIDELINE FOR PACKERS/RE- PACKERS

This section is intended for Packers and Re-packers, where the traceable item may be a Trade Item (packaging product) that goes to Retail Point-of-Sale (POS Trade Item) or a Trade Item (packaging product) that does not go to a Retail Point-of-Sale (Non-POS Trade Item).

Examples of Packers/Re-packers are:

•Agricultural Cooperative

•Packing House

•Retail Pack House (e.g. Produce, Poultry, etc.)

•Retail Store (which re-packs or re-labels)

3.1Identification of the organization

Packers/Re-packers need to use the Business Identification number (BID) to identify the organization they manage and then share that number with suppliers and customers. The BID is allocated by the Ministry of Health or any other designated government agency which maintains the National Business Registry for Food Operators.

Individual BIDs can be assigned to represent the organization as well as any individual trading subsidiaries.

3.2Capturing production inputs

To enable traceability, packers/re-packers must maintain records of essential information related to the product they receive (e.g. produce, packaging material, etc.).

3.2.1Information that must be recorded when buying or receiving, and retained

Suppliers deliver their products in bulk using various containers or bags for transport (Trade Items). Common examples of Trade Items include bags, totes, bins and trailers. Each Trade Item must be traceable. For this reason, each Trade Item should carry a tag or label that shows the information about its content. This information guarantees uniqueness across all growing companies providing the product. Each time a product is received for packing, the following information must accompany the tag or label attached to the Trade Item:

•Supplier’s BID (Farm Id)

•Supplier’s name

•Commodity name and, where applicable, variety name

•Lot number (typically harvesting date)

•Code for date marking as required by relevant legislation

•Quantity

Packers/Re-packers must also retain a copy of the Sales Receipt given by the Supplier (or given by the Packer/Re-packer to the Supplier in the absence of). The Sales Receipt copy shall have at least the following information:

•Supplier/Seller name

•Supplier/Seller contact information

•Supplier BID

•Customer name

•Customer BID

•Product Description (Brand name if applicable, including variety

•Lot number or other batch identifier of the good (i.e. harvesting date)

•Quantity and packaging information

•Date of transaction

•Origin Address: Address from where the good was delivered

•Destination Address: Address of receiving location/trading partner

•Name and contact information of the transporter

•Any other information deemed appropriate by the Competent Authority

It is recommended to also record the receiving information in a record keeping system (paper or electronic form). In this case it is recommended that the following information is included:

•Sales Receipt number

•Product identification number (if available)

•Name of person who received the product

•Name of person who dispatched the product from the supplier

3.3Identification of trade items and packer/re-packer information

Each time a Trade Item is created and destined for a subsequent trading partner, this must be identified. Examples of Trade Items include trays, bags, cartons, pallets and others.

To assist customers with their subsequent traceability, Packers/Re-Packers shall attach to their Trade Items a label, in human-readable format, with all relevant traceability information. Products are labeled at the time of packaging or distribution.

There are two types of Trade Items that can be created by a Packer/Re-Packer:

•POS Trade Items: Trade items that go to Retail Point of Sale (POS). Normally Consumer Units.

•Non-POS Trade Items: Trade items that never go to Retail Point of Sale (POS). Normally industrial products, logistic units, bulk products and others.

Depending on the type of Trade Item there are different requirements to identify them and to label them.

3.3.1Identification of production batches/lots

All packers/re-packers must assign a batch/lot number to products they create. The batch/lot number itself can vary from one organization to another, depending on the precision desired. For example, a batch/lot number can represent a day’s packing or the product packed from an individual packing line. Packer/re-packer batch/lot numbers must be internally linked to the original grower/harvest information.

It is important to remember that the batch/lot number relates to the scope of products that may be implicated in a recall and this needs to be considered during assignment.

3.3.2How to identify Non POS Trade Items

For packers and re-packers, outbound Trade Items are typically bags, cases or containers. To identify Non POS Trade Items, the use of at least the Business ID (BID), the Commodity name and the associated production batch/lot number is required.

3.3.2.1Guidelines for labeling Non POS Trade Items:

Each Non POS Trade Item should provide the following data in human-readable format:

•Packer/Re-packer Name

•BID

•Commodity name and, where applicable, variety name

•Batch/Lot number (it is recommended to use the packing date)

•Code for date marking as required by relevant legislation

•Quantity

•Additional information required by relevant legislation (e.g. weight, price, Country of Origin, etc.)

3.3.3Identification of POS Trade Items

To identify packaged products that go to a Point-of-Sale (POS Trade Items) the use of at least the Business ID (BID), the Commodity name and the associated production batch/lot number is required. Some retailers also may ask for the use of a GS1 Global Trade Item Number (GTIN) to identify trade items, so the use of this standard identification in addition to the Commodity name is recommended.

3.3.3.1Global Trade Item Number

The Global Trade Item Number (GTIN) is a standardized and globally unique way to identify items traded in the supply chain. Where there is a requirement to accurately order, invoice, price or receive your product, the GTIN is the basic enabler. The GTIN provides a common language to support multiple business practices, including traceability. Where a product is sold under a brand name, the brand owner is responsible for assigning the GTIN.

3.3.3.2Assigning a GTIN to the traded items produced by a company

Where product is sold under a brand name, the brand owner is responsible for assigning the GTIN. If the organization is the brand owner, the first step is to apply for a GS1 Company Prefix with a GS1 representative (normally the Bureau of Standards). If the company producing the item is not the brand owner, then brand owner’s GTIN must be used.

See Appendix 1 – Section 9.1 for more information about GTIN assignment.

3.3.3.3Guidelines to Label POS Trade Items:

Labels provide the means for identifying POS Trade Items to other trading partners. The label shows the product identifier (i.e. Product Identification number or GTIN if available) and associated batch/lot number in an easy-to-read human-readable form and, if required by the customer (usually retailers), should also provide product information using a GS1-compliant bar code. This ensures that the POS Trade Items can be identified quickly and accurately at any POS, anywhere in the world.

Additional information about creating GS1-compliant bar codes is at Appendix 1 – Section 9.1.1.

Each trade item label should provide the following data in human-readable format:

•Grower/Packer’s Name

•BID

•Commodity name and, where applicable, variety name

•GTIN

•Batch/Lot number (the use of packing date is recommended)

•Code for date marking, as required by relevant legislation

•Quantity

•Additional information required by relevant legislation (e.g. weight, price, address, best before date, Country of Origin, etc.)

3.4Traceability Information to be recorded

Traceability data is recorded (paper or electronic form) to ensure that the traceability link is maintained. The following list represents the minimum data required to ensure traceability between suppliers (i.e. growers) and trading partners (i.e. customers) of a company.

•Packer/Re-Packer’s Name

•Packer/Re-Packer’s BID

•Product Description (Brand name if applicable, including variety)

•Lot number or other batch identifier of the good (i.e. Packing Date)

•Shipped from location identification (i.e. shipping address)

•Shipped to location identification (i.e. address of receiving location/trading partner)

•Date of dispatch/shipment

•Name and contact information of the transporter

•Any other information deemed appropriate by the Competent Authority

It is recommended that the following information should also be recorded:

•Product identification number (GTIN, if available)

•Sales Receipt number

•Name of person who received the product

•Name of person who dispatched the product

Additionally, the organization must retain a copy of the Sales Receipt given to the Trading Partner (i.e. customer). The Sales Receipt copy shall have at least the following information:

•Packer/Re-packer’s Name

•Packer/Re-packer’s contact information

•Packer/Re-packer’s BID

•Customer’s name

•Customer’s BID

•Product Description (Brand name if applicable, including variety)

•Lot number or other batch identifier of the goods (i.e. harvesting date)

•Quantity and packaging information

•Date of transaction

•Origin Address: Address from where the goods was delivered

•Destination Address: Address of receiving location/trading partner

•Name and contact information of the transporter

•Any other information deemed appropriate by the Competent Authority

It is recommended that the following information should also be included:

•Sales Receipt number

•Product identification number (GTIN, if available)

•Price

•Name and signature of person who received the product

•Name and signature of person who dispatched the product from the supplier

Data attribute definitions are provided in the Glossary of Terms (see Section 8).

3.5Data retention

All organizations are expected to maintain records that will facilitate timely and accurate traceability and support any product recalls.

Records are retained at a registered location or at another readily available location and made available to the Competent Authority within the time limit prescribed by [rule/order] approved by the Competent Authority.

3.6Recall and withdrawal

Packers/Re-Packers needs to develop a recall strategy containing the following elements:

•depth of recall, which may extend to the consumer level, the retail level, or the wholesale level;

•the contents of public notifications to be issued depending on the classification and severity of the grounds for which a recall is issued;

•public warning that is given nationwide or to affected geographical areas during urgent situations;

•effectiveness check level, which includes the method to be used for and depth recall effectiveness checks; and

•the disposal of recalled products.

It is recommended that at least one Mock Recall (simulation) should be carried out every year to test the strategy and the requirements.

3.6.1Recalls requested by Competent Authority

For recalls requested by the Competent Authority, the following actions are undertaken by Packers / Re-Packers after the request to initiate the recall:

•stop the distribution of the product;

•withdraw the product from the market;

•notify the public, trading partners and consignees of a recall as prescribed;

•effectively and accurately inform the consumers of the reason for the recall and, if necessary, recall from consumers the products that have already been supplied to them (when other measures are not sufficient to guarantee food safety), following the procedures established by the Competent Authority;

•issue a press release if so directed by the Competent Authority; and

•abide by other recall requirements as may be established by the Competent Authority.

The recall is terminated when the Competent Authority determines that all reasonable efforts have been made to remove or correct the product in accordance with the recall strategy, and when it is reasonable to assume that the product subject to the recall has been removed and proper disposal or correction has been made commensurate with the degree of hazard of the recalled product. The appropriate authority would then issue written notification to the Packer/Re-Packer that the recall Is terminated.

3.6.2Voluntary recalls

For voluntary recalls, the implementation of the following actions is recommended:

•If the Packer/Re-Packer considers or has reason to believe that a food item which it has locally distributed is not in compliance with the food safety requirements, it shall immediately initiate procedures to withdraw the food in question from the market (where the food has left the immediate control of that initial food business operator) and inform the competent authorities.

•Where the product may have reached the consumer, the Packer/Re-Packer shall effectively and accurately inform the consumers of the reason for its withdrawal, and if necessary, recall from consumers the products that have already been supplied to them, when other measures are not sufficient to achieve a high level of health protection.

•The Packer/Re-Packer shall immediately inform the competent authorities if it considers or has reason to believe that the food which it has placed on the market may be injurious to human health. Also, it shall inform the competent authorities of the action taken to prevent risks to the final consumer.

3.7Business scenarios for packers/re-packers

3.7.1Scenario 1: Shed (packinghouse) packed product (fresh produce)

3.7.1.1Description of the process

The process starts when the packinghouse receives the produce the packaging material and other inputs. The packaging material and inputs may be received from multiple suppliers (manufacturing companies) and the produce from local farmers. All the packaging material, inputs and produce may contain multiple batch/lot numbers. In the packinghouse the following activities are conducted on the product:

•Sorting/grading

•Packing (under Target Packers’ Brand)

•Cooling

•Storing

•Selling

•Shipping

When packing, a label with the product name/description, product identification number (GTIN if applicable) and batch/lot number is assigned.

After the final products are prepared, these are sent to be displayed in the store.

3.7.1.2Description of the traceability process for packinghouses

•Receiving process

The product is harvested in the field at the grower’s farm and placed in bins or bags (Trade Items) which are brought by truck to the Packinghouse. These Trade Items serve as the traceable unit between the Farm and the Packinghouse. A human-readable “field tag” is applied by the grower to the bin or bags used to transport the produce.

When the truck arrives at the Packinghouse, the product is moved to a holding area until it is to be packed. When receiving, the Packinghouse must verify that all the received products are properly identified with a label (or tag) showing the following information:

-Supplier Name

-Supplier BID

-Commodity Description

-Harvesting Date (dd/mm/yy)

-Quantity

Note: Labels must be attached by the farmer at origin or by the packinghouse when receiving and transferring the products to their own bins or containers.

The Packinghouse must keep a record with the information of all the products received using the sales receipt given by the supplier (one copy retained by the packinghouse, one copy remains with the supplier) (see Appendix 2 – Section 10.1.3). The information to be recorded in the sales receipt is as follows:

-Supplier Name, BID and Delivery Address

-Product received

-Batch number or Harvesting Date (dd/mm/yy)

-Receiving Date (dd/mm/yy)

-Quantity

-Receiving facility Name and Receiving Address and Packinghouse BID

Note: If it is not possible to obtain a Sales Receipt from the Supplier with the required traceability information, then the Packinghouse must record the required information using the Input Control Form (see Appendix 2 – Section 10.2.2) and staple this together with the invoice given by the supplier.

The Packinghouse shall also keep a record with the information of all the packaging material and inputs received using the sales receipt given by the supplier (one copy given to the packinghouse, one copy retained by the supplier). The information to be recorded in the sales receipt is as follows:

-Supplier Name, BID and Delivery Address

-Product received

-Batch/Lot number

-Receiving Date (dd/mm/yy)

-Quantity

-Receiving facility Name, Address and Packinghouse BID

Note: If it is not possible to obtain a Sales Receipt from the packaging material or input supplier, then the packinghouse must record the required information using the Input Control Form (see Appendix 2 – Section 10.2.2) and staple this together with the invoice given by the supplier using the sample given.

•Processing and packaging

When it is time to pack the produce, the raw product is retrieved from the holding area and brought to a packing area where the product is placed onto the packing line. Before the packing begins, the Packinghouse assigns a batch/lot number to the production run.

When a different product (commodity/variety) or a product from a new field is brought to the packing line, there should be a pause to allow for the completion of the packing of the product from the previous production run and a new batch/lot number is assigned to the next production run.

After the product is graded and packed into containers (e.g. cartons, cases, bags, etc.), a label is applied to the carton containing human-readable information about the product.

When packing and preparing the final product, the Processing/Packing form (see Appendix 2 – Section 10.2.1) should be used to record the following processing information:

-Product Description

-GTIN (if applicable)

-Quantity

-Batch Number

-Packing Date

-Raw Material used during the process (Product code, Product Name, Supplier BID, Batch/Lot, Quantity)

-Ingredients used during the process (Product code, Product Name, Supplier BID, Batch/Lot, Quantity)

-Packaging material used (Product code, Product Name, Supplier BID, Batch/Lot, Quantity)

The container (e.g. carton, bag, case, etc.) with the final product is labeled (see image) with the following information:

-Plant name

-BID

-Product Description

-Packing Date

-Batch number

-Quantity

•Delivery process

When products are delivered, an invoice or shipment receipt (see Appendix 2 – Section 10.3.3) is issued (one copy given to the customer, one copy retained by the processor). The information to be recorded in this receipt is as follows:

-Processor Name, BID and Delivery Address

-Product Description

-Packing Date

-Batch number

-Quantity

-Receiving facility name, address and BID (if it applies)

3.7.2Scenario 2: Produce processing/packing at the supermarket

3.7.2.1Description of the process

The process starts when the produce and packaging material are received at the Supermarket. The packaging material may be received from multiple suppliers (manufacturing companies) and the produce from local farmers or imported. All of the packaging material and produce may contain multiple batch/lot numbers.

The Supermarket prepares a final product to be displayed in the store. There are three alternatives:

1.Send the product directly to the store without any process to be presented in bulk format

2.Repack the product that comes from the processor

3.Prepare a new final product with multiple products and batch/lot numbers into a new package.

In the first case, it is not necessary to apply labels as the products are going to be displayed in bulk in the store. In this case, the supermarket should, at all times, record the product identification when sending it to the store.

In the second and third cases, a label with the product name/description, product identification number (GTIN if applicable) and batch/lot number is assigned.

After the final products are prepared, these are sent to be displayed in the store.

3.7.2.2Description of the traceability process for supermarkets

•Receiving process

When receiving, the supermarket must verify that all the received products are properly identified with a label (or tag) showing the following information:

-Supplier Name

-Supplier BID

-Commodity Description

-Harvesting Date (dd/mm/yy)

-Quantity

Note: Labels must be attached by the farmer at origin or by the supermarket when receiving and transferring the products to their own bins or containers.

The supermarket must keep a record with the information of all the products received using the sales receipt given by the supplier (one copy retained by the supermarket, one copy remains with the supplier) (see Appendix 2 – Section 10.1.3). The information to be recorded in the sales receipt is as follows:

-Supplier Name, BID and Delivery Address

-Product received

-Batch number or Harvesting Date (dd/mm/yy)

-Receiving Date (dd/mm/yy)

-Quantity

-Receiving facility Name and Receiving Address and Supermarket BID

Note: If it is not possible to obtain a Sales Receipt from the Supplier with the required traceability information, then the supermarket must record the required information using the Input Control Form (see Appendix 2 – Section 10.2.2) and staple this together with the invoice given by the supplier.

The supermarket must also keep a record with the information of all the packaging material received using the sales receipt given by the supplier (one copy is given to the supermarket, one copy is retained by the supplier). The information recorded in the sales receipt is as follows:

-Supplier Name, Business Identification Number and Delivery Address

-Product received

-Batch/Lot number

-Receiving Date (dd/mm/yy)

-Quantity

-Receiving facility Name, Address and Supermarket Business ID Number

Note: If it is not possible to obtain a Sales Receipt from the packaging material supplier, then the supermarket must record the required information using the Input Control Form (see Appendix 2 – Section 10.2.2) and staple this together with the invoice given by the supplier using the sample given.

Processing and display in store

When preparing a final product to be displayed in the store, the following information should be recorded in the Processing / Packing form (see Appendix 2 – Section 10.2.1):

-Product Description

-GTIN (if applicable)

-Batch Number

-Packing Date

-Quantity

-Raw Material used during the process (Product code, Product Name, Supplier BID, Batch/Lot, Quantity)

-Packaging material used (Product code, Product Name, Supplier BID, Batch/Lot, Quantity)

All the final products are labeled (See image) with the Supermarket name, BID, Product Description, Product Code (GTIN if applicable) and Batch number.

If the received products are sent to be displayed in bulk in the store (without any processing) the supermarket must have the knowledge, via records, of what they have displayed at the store. The Processing / Packing form can be used for this purpose (see Appendix 2 – Section 10.2.1). The information to record is as follows:

-Product Description

-GTIN (if applicable)

-Batch Number

-Produce displayed (Product code, Product Name, Supplier BID, Batch/Lot, Quantity). If there is a mixed product (mixed from more than one farmer), then the information of the product in the mix from each farmer must be recorded (See example below).

3.7.3Scenario 3: Processing/packing plant (supermarket) repacks poultry received from suppliers

3.7.3.1Description of the process

The process starts when the raw material (whole chicken or parts), ingredients and packaging material are received in the Processing Facility and stored waiting to be used to prepare the final product. The ingredients and packaging material may be received from multiple suppliers (manufacturing companies) and raw material (chicken) from local processors. All of the ingredients, packaging material and raw material may contain multiple batch/lot numbers.

Then the Supermarket processing facility prepares a final product to be sent to the stores. There are three alternatives:

1.Send the product directly to the store without any process

2.Repack the product that comes from the processor

3.Prepare a new product. Maybe different cuts and/or adding ingredients (i.e. seasoning).

In the first case, it is not necessary to apply a label, as the products are sent to the stores with the same identification assigned by the supplier.

In the second and third cases, a label with the product name/description, product identification number (GTIN if applicable) and batch/lot number is assigned.

After the final product is prepared, these are sent to the stores.

3.7.3.2Description of the traceability process for processing/packing plant:

•Receiving Process

When receiving, the supermarket Processing/Packing Plant must verify that all the received products are properly identified with a label (or tag) showing the following information:

-Supplier Name

-Supplier BID

-Product Description

-Packing Date (dd/mm/yy)

-Batch number

-Quantity

Note: Labels must be attached by the processors at origin or by the supermarket processing/packing plant when receiving and transferring the products to their own bins or containers.

The supermarket must keep a record with the information of all the products received using the sales receipt given by the supplier (one copy retained by the supermarket, one copy remains with the supplier) (see Appendix 2 – Section 10.8.3). The information to be recorded in the sales receipt is as follows:

-Supplier Name, BID and Delivery Address

-Product received

-Batch number

-Receiving Date (dd/mm/yy)

-Quantity

-Receiving facility Name, Address and Supermarket BID

Note: If it is not possible to obtain a Sales Receipt from the Supplier with the required traceability information, then the supermarket must record the required information using the Input Control Form (see Appendix 2 – Section 10.3.1) and attach the invoice given by the supplier.

The supermarket also must keep a record with the information of all the ingredients and packaging material received using the sales receipt given by the supplier (one copy given to the supermarket, one copy retained by the supplier). The information to be recorded in the sales receipt is as follows:

-Supplier Name, Business Identification Number and Delivery Address Product received

-Batch/Lot number

-Receiving Date (dd/mm/yy)

-Quantity

-Receiving facility Name, Address and Supermarket Business ID Number

Note: If it is not possible to obtain a Sales Receipt from the input supplier, then the supermarket must record the required information using the Input Control Form (see Appendix 2 – Section 10.3.1) and attach the invoice given by the supplier using the sample given.

•Processing

When preparing a final product, the Processing/Packing form (see Appendix 2 – Section 10.3.2) should be used to record the following manufacturing information:

-Product Description

-GTIN (if applicable)

-Quantity

-Batch Number

-Packing Date

-Raw Material used during the process (Product code, Product Name, Supplier BID, Batch/Lot, Quantity)

-Ingredients used during the process (Product code, Product Name, Supplier BID, Batch/Lot, Quantity)

-Packaging material used (Product code, Product Name, Supplier BID, Batch/Lot, Quantity)

The container with the final products to be sent to the store is labeled (see image) with the following information:

-Plant name

-BID

-Product Description

-Packing Date

-Batch number.

-Quantity

Note: If the received products are not processed and are sent to be displayed in the store, it is not necessary to record information as there is no process to record. However, the Processing/Packing Plant must provide a label with the required information (see above) attached to every container used to send the products to the store.

•Delivery Process

When products are delivered to the stores, an invoice or shipment receipt (see Appendix 2 – Section 10.3.3) is issued (one copy given to the store, one copy retained by the processor). The information to record in this receipt is as follows:

-Processor Name, BID and Delivery Address

-Product Description

-Packing Date

-Batch number

-Quantity

-Receiving facility name, Address and BID

3.7.4Scenario 4: Processing/packing at the store (supermarket)

3.7.4.1Description of the process

The process starts when the raw material (whole chicken or parts), ingredients and packaging material are received and stored at the Supermarket Store. The raw material (chicken) is received from the processing/packing plant. The ingredients and packaging material may be received from the Supermarket Depot or from multiple suppliers (manufacturing companies). All of the ingredients, packaging material and raw material may contain multiple batch/lot numbers and are held at the Store until ready for use in the preparation of the final product.

The Store has three alternatives:

1.Relabeling the product that comes from the processor to add the price

2.Prepare a new packed product. Maybe different cuts and/or adding ingredients (i.e. seasoning).

3.Prepare a new product using some ingredients (i.e. seasoning) to be displayed in the rotisserie.

In the first two cases a label with the product name/description, product identification number (GTIN if applicable) and batch/lot number is assigned. After the final product is prepared and labeled, this is sent to be displayed in the store.

In the third case all the ingredients and raw material used should be recorded. The period for recording the information depends on the supermarket but should not go beyond the opening hours of the Store.

3.7.4.2Description of the traceability process for the supermarket store:

•Receiving process

When receiving processed products from the processing/packing plant (product that will be displayed in its original packaging from the poultry processor), the Store must verify that they are properly identified with a label (or tag) showing the following information:

-Supplier Name

-Supplier BID

-Product Description

-Packing Date (dd/mm/yy)

-Batch number

-Quantity

When receiving processed products from the processing/packing plant, the Store must verify that the received products from the processing/packing plant are properly identified with a label (or tag) showing the following information:

-Plant name

-BID

-Product Description

-Packing Date

-Batch number

-Quantity

The supermarket must keep a record with the information of all the products received using an Invoice or the shipment receipt given by the processing/packing plant (one copy retained by the supermarket, one copy remains with the processing/packing plant) (see Appendix 2 – Section 10.3.3). The information to be recorded in the invoice/receipt is as follows:

-Supplier Name, BID and Delivery Address

-Product received

-Batch number

-Receiving Date (dd/mm/yy)

-Quantity

-Receiving facility Name, Address and Supermarket BID

The supermarket also must keep a record with the information of all the ingredients and packaging material received using an invoice given by the Depot or a sales receipt given by the supplier (one copy given to the supermarket, one copy retained by the supplier). The information to be recorded in the sales invoice/sales receipt is as follows:

-Supplier Name, BID and Delivery Address

-Product received

-Batch/Lot number

-Receiving Date (dd/mm/yy)

-Quantity

-Receiving facility Name, Address and Supermarket BID

Note: If it is not possible to obtain a Sales Receipt from the input supplier, then the supermarket must record the required information using the Input Control Form (see Appendix 2 – Section 10.3.1) and staple this together with the invoice given by the supplier using the sample given.

•Processing and display in the store

When preparing a final packed product, the Processing/Packing form (see Appendix 2 – Section 10.3.2) should be used to record the following manufacturing information:

-Product Description

-GTIN (if applicable)

-Batch Number

-Packing Date

-Quantity

-Raw Material used during the process (Product code, Product Name, Supplier BID, Batch/Lot, Quantity)

-Ingredients used during the process (Product code, Product Name, Supplier BID, Batch/Lot, Quantity)

-Packaging material used (Product code, Product Name, Supplier BID, Batch/Lot, Quantity)

For the products that are displayed in the Rotisserie, the Store must have the knowledge, based on records, of the products and ingredients used in its preparation. The Processing/Packing form can be used for this purpose (see Appendix 2 – Section 10.3.2). The information to record is as follows:

-Product Description

-GTIN (if applicable)

-Batch Number

-Processing Date

-Quantity

-Raw Material used during the process (Product code, Product Name, Supplier BID, Batch/Lot, Quantity)

-Ingredients used during the process (Product code, Product Name, Supplier BID, Batch/Lot, Quantity)

-Packaging material used (Product code, Product Name, Supplier BID, Batch/Lot, Quantity)

All the final products are labeled with the following information (see image):

-Supermarket name

-BID

-Product Description

-Product Code (GTIN if applicable)

-Packing Date or Batch number

4    IMPLEMENTATION GUIDELINE FOR DISTRIBUTORS/TRADERS

This section is intended for Distributors/Traders where the traceable item would usually be a Trade Item (packaging product or logistic unit) that does not go to a Retail Point-of-Sale (Non-POS Trade Item). Examples of Distributors/Traders are:

•Agricultural Cooperative

•Retail or Food service Distribution Centre

•Import and Export Warehouses

•Wholesaler

•Terminal

4.1Identification of the organization

Distributors/Traders need to use the Business Identification number (BID) to identify the organization they manage and then share that number with suppliers and customers. The BID is allocated by the Ministry of Health or any other designated government agency which maintains the National Business Registry for Food Operators.

Individual BIDs can be assigned to represent your organization as well as any individual trading subsidiaries.

4.2Capturing inputs

Distributors/traders must capture traceability information from the products (trade items) they receive from suppliers. These products are identified using a label with the Supplier’s BID, the Commodity name and the Lot/Batch number. Traceability is accomplished by associating each Supplier’s BID and Commodity name with its batch/lot number. This information is recorded.

To enable traceability, distributor/traders could also maintain records of other product inputs (e.g. packaging material) for their own use. This information could be critical to a company’s body of internal traceability information, however it is not absolutely necessary.

4.3Identification of trade items

Where distributors/traders simply re-sell a product from their suppliers (i.e. products are not re-packaged into other traded units), they must use the product information assigned by the suppliers to inbound products.

Where distributors re-configure product received from suppliers, they are required to assign a new identification and label for each new product.

4.3.1Identification of production batches/lots by a company

All distributors/traders must assign a batch/lot number to products they create. The batch/lot number itself can vary from one company to another, depending on the desired precision. For example, a batch/lot can represent a day’s production or the product produced from an individual processing or packing line.

It is important to remember that a company’s batch/lot relates to the scope of products that may be implicated in a recall and needs to be considered during assignment.

4.4Identification of logistic units

For distributors/traders, outbound logistics units are typically cases, pallets or containers. When a company’s traceable item is one or more logistic units, the best business practice is to assign a Serial Number to each logistic unit. Each Serial Number that is assigned is unique to the individual logistic unit. There are no legal requirements to identify logistic units.

4.4.1Case and logistic unit labels

4.4.1.1Guidelines for Non POS Trade Items labels

When the traceable item is the product (Non POS Trade Item), labels provide a means of identifying that product to other trading partners. The label shows the product identifier (i.e. BID and Commodity Name) and associated batch/lot numbers in an easy-to-read human-readable form. This ensures that cases can be identified at any subsequent point in the supply chain.

It should be noted that where the company’s case product is sold to consumers in the case (i.e. the case is sold at retail Point-of-Sale), then a bar code symbol should be used to enable front end and POS scanning. If this is required by the customer, then the customer should be asked to provide assistance with using a bar code that can be scanned at their POS.

If the traceable item is the logistic unit (i.e. each logistic unit needs to be uniquely identified and tracked), refer to the guidelines below for logistic unit labels.

4.4.1.2Guidelines for Logistic unit labels:

When the traceable item is a logistic unit (e.g. pallet, container), the labels provide a means of identifying that shipping container to other trading partners. The label shows the logistic unit identifier (i.e. Serial Number) in an easy to read (human-readable) form. Additional information may be shown on the pallet label. This is usually determined by customer-specific relationships.

There is no minimum requirement to identify logistics units. All that is needed is the assignment of a tag or a label to the logistic unit with a Serial Number. This will help in physically locating the logistic unit and relating it to the contents within.

The best practice with regard to labeling a logistic unit is the use of GS1-compliant bar codes to provide the necessary information. This ensures that pallets can be identified quickly and accurately at any subsequent point in the supply chain, anywhere in the world. Pallet bar codes (i.e. symbols) conform to a symbol called GS1-128 (To learn more about GS1-compliant bar codes, see Appendix 1 – Section 9.1.1.).

4.5Traceability information to be recorded

To ensure that the traceability link is maintained, data must be recorded. The following represents the minimum data required to ensure traceability between the suppliers and customers of a company.

•When the supplier’s product (package/case) is the traceable item

○Supplier’s Name

○BID

○Product Description (Brand name if applicable, including variety)

○Lot number or other batch identifier of the good

○Shipped from location identification (i.e. shipping address)

○Shipped to location identification (i.e. address of receiving location/trading partner)

○Date of dispatch/shipment

○Sales Receipt Number

○Transporter Information (e.g. name, address, telephone number, and, if available fax number and email)

○Trade item quantity and unit of measure

○Any other information deemed appropriate by the Competent Authority

•When the supplier’s logistic unit is the traceable item

○Supplier’s Name

○BID

○Product Description (Brand name if applicable, including variety)

○Serial Number

○Shipped from location identification (i.e. shipping address)

○Shipped to location identification (i.e. address of receiving location/trading partner)

○Receiving date

○Sales Receipt Number

○Transporter Information (e.g. name, address, telephone number, and, if available fax number and email)

○Any other information deemed appropriate by the Competent Authority

•When the company’s (outbound) traceable item is a package/case (Non POS Trade Unit)

○Distributor/Trader BID

○Distributor/Trader name

○Trade item description

○Batch/lot number

○Trade item quantity and unit of measure

○Shipped from location (i.e. shipping location address)

○Shipped to location (i.e. address of receiving location/trading partner)

○Date of shipment

○Sales Receipt Number

○Transporter Information (e.g. name, address, telephone number, and, if available fax number and email)

•When the company’s (outbound) traceable item is the logistic unit

○Distributor/Trader BID

○Distributor/Trader name

○Logistic unit Serial Number

○Shipped from location (i.e. shipping location address)

○Shipped to location (i.e. address of receiving location/trading partner)

○Date of shipment

○Sales Receipt Number

○Transporter Information (e.g. name, address, telephone number, and, if available fax number and email)

○Any other information deemed appropriate by the Competent Authority

•When the company’s (outbound) traceable item is a shipment

○Distributor/Trader BID

○Distributor/Trader name

○Unique shipment identifier (e.g. may be the bill of lading number)

○Shipped from location (i.e. shipping location address)

○Shipped to location (i.e. address of receiving location/trading partner)

○Date of shipment

○Sales Receipt Number

○Transporter Information (e.g. name, address, telephone number, and, if available fax number and email)

○Any other information deemed appropriate by the Competent Authority

Additionally, the company also retains a copy of the Sales Receipt given to the customers. The Sales Receipt copy should have at least the following information:

•Distributor/Trader Name

•Distributor/Trader BID

•Customer’s name

•Customer BID

•Product Description (Brand name if applicable, including variety)

•Lot number or other batch identifier of the good

•Quantity and packaging information

•Date of transaction

•Origin Address: Address from where the good was delivered

•Destination Address: Address of receiving location/trading partner

•Name and contact information of the transporter

•Any other information deemed appropriate by the Competent Authority

Data attribute definitions are provided in the Glossary of Terms (see Section 8).

4.6Data retention

All organizations are expected to maintain records that will facilitate timely and accurate traceability and support any product recalls.

Records are retained at a registered location or at another readily available location and made available to the Competent Authority within the time limit prescribed by [rule/order] approved by the Competent Authority.

4.7Recall and withdrawal

Distributors/Traders need to develop a recall strategy containing the following elements:

•depth of recall, which may extend to the consumer level, the retail level, or the wholesale level;

•the contents of public notifications to be issued depending on the classification and severity of the grounds for which a recall is issued;

•public warning that is given nationwide or to affected geographical areas during urgent situations;

•effectiveness check level, which includes the method to be used for and depth recall effectiveness checks; and

•the disposal of recalled products.

It is recommended that at least one Mock Recall (simulation) should be carried out every year to test the strategy and the requirements.

4.7.1Recalls requested by Competent Authority

For recalls requested by Competent Authority, the following actions are undertaken by Distributors / Traders after the request has been received to initiate the recall:

•stop the distribution of the product;

•withdraw the product from the market;

•notify the public, trading partners and consignees of a recall as prescribed;

•effectively and accurately inform the consumers of the reason for the recall and, if necessary, recall from consumers the products that have already been supplied to them (when other measures are not sufficient to guarantee food safety), following the procedures established by the Competent Authority;

•issue a press release if so directed by the Competent Authority; and

•abide by other recall requirements as may be established by the Competent Authority.

The recall is terminated when the Competent Authority determines that all reasonable efforts have been made to remove or correct the product in accordance with the recall strategy, and when it is reasonable to assume that the product subject to the recall has been removed and proper disposal or correction has been made commensurate with the degree of hazard of the recalled product. The appropriate authority will issue written notification to the Distributor/Trader that a recall is terminated.

4.7.2Voluntary recalls

For voluntary recalls, implementation of the following actions is recommended:

•If the Distributor/Trader considers or has reason to believe that the food which it has locally distributed is not in compliance with the food safety requirements, it shall immediately initiate procedures to withdraw the food in question from the market where the food has left the immediate control of that initial food business operator and inform the competent authorities.

•Where the product may have reached the consumer, the Distributor/Trader shall effectively and accurately inform the consumers of the reason for its withdrawal, and if necessary, recall from consumers the products that have already been supplied to them, when other measures are not sufficient to achieve a high level of health protection.

The Distributor/Trader shall immediately inform the competent authorities if it considers or has reason to believe that the food which it has placed on the market may be injurious to human health. Also, it shall inform the competent authorities of the action taken to prevent risks to the final consumer.

4.8Business scenarios for distributors/traders

4.8.1Scenario 1: Distributor receives imported product from a grower/exporter

4.8.1.1Description of the Process

The Island Distribution Company is a re-seller of products that is sourced from growers/exporters.

The Island Distribution Company trace Trade Items received from suppliers at the case level. Island Distribution also traces Trade Items on outbound distribution.

4.8.1.2Description of the Traceability Process

•Receiving Process

When the product arrives at Island Distribution, it is unloaded and verified against the information previously received and with the information on the “Sales Receipt”. Then, the product is palletized and the pallet tagged with a Serial Number which is placed on each pallet. Likewise, if the grower/exporter does not identify a batch/lot number for each case, a unique number such as the shipment identification from the grower/shipper documentation is assigned as a batch/lot number.

•Processing

The product is stored pending sale and shipment to a customer.

•Delivery Process

Once the pallet is ready to be shipped to a customer, Island Distribution records the outbound pallet Serial number for each pallet on a shipment/order so they can identify exactly what is on the shipment and the product begins its journey to the next stage in the supply chain.

Each load of product being shipped from Island Distribution Company should also be conveyed via a “Sales Receipt” or “trip” ticket that is sent to the next stage in the supply chain.

4.8.2Scenario 2: Distributor receives and re-distributes produce from packers /others distributors/ traders (including cooperatives, brokers, auctions)

4.8.2.1Description of the Process

Veggie Fresh Produce is a large distributor of fresh fruit and vegetables that markets products under the brand names of Major Packers and under their own “Veggie Fresh” brand. Veggie Fresh performs multiple roles within the supply-chain process and has accountability for the receipt and shipment of products that will include traceability data.

The roles that Veggie Fresh can play in the supply-chain include:

•The receiver of products from the source of goods which can include a field, packing house, or production facility. Consequently, Veggie Fresh may perform the role of packer, re-packer or distributor/trader.

•The receiver of products from another distributor in the supply-chain. Veggie Fresh performs the role of distributor/trader.

•A supplier of products to an end customer such as a retail store, restaurant, or other points of consumption.

•A supplier of products to a distribution point that ships the product to a retail store, restaurant, or other points of consumption.

•Receiver of products that are returned or rejected from a supplied entity.

Veggie Fresh is responsible for the capture, retention and communication of traceability data for the product that is managed. Veggie Fresh and its trading partners need to track at the product level.

4.8.2.2Description of the Traceability Process

•Receiving Process

At the point of receipt, Veggie Fresh is responsible for receiving each item ordered with the associated Supplier’s Business ID, Commodity Name, batch/lot, quantity received, and date. This information reflects the initial point of control. This data must be recorded. The expectation of Veggie Fresh is that the batch/lot information provided by growers can be linked back to the field, packing house, or production of the product. Also, the Supplier’s Sales Receipt must be stored and its number linked with the previous records.

If the item received from the source of goods includes multiple batch/lots for the same product, each product (Supplier’s ID and Commodity Name) and associated batch/lot must be recorded along with the quantity received.

If the product is received due to a rejection or return, the information for the product (Supplier’s ID and Commodity Name), batch/lot, quantity, and receipt date must be captured and recorded.

•Processing

Following the receipt of products into the facility, Veggie Fresh is responsible for the retention of data associated to each product (Supplier’s ID and Commodity Name) and batch/lot within their facility.

At the point of pick-up, it is recommended that Veggie Fresh captures information for each product (Supplier’s ID and Commodity Name) and batch/lot for the products that are to be shipped.

•Delivery Process

At the point of product shipment, Veggie Fresh provides the receiving entity with the product (Supplier’s ID and Commodity Name), original batch/lot number from source, and quantity for each item shipped.

Each load of product being shipped from Veggie Fresh should also be conveyed via a “Sales Receipt” or “trip” ticket that is sent to the next stage in the supply chain.

5    MANUFACTURER / PROCESSORS

This section is intended for Manufacturers/Processors where the traceable item would usually be a Trade Item (packaging product) that goes to Retail Point-of-Sale (POS Trade Item), but sometimes they can manufacture a Trade Item (packaging product) that doesn’t go to a Retail Point-of-Sale (Non-POS Trade Item). Normally manufacturers/processors can use ingredients and/or raw material to manufacture their products or simply process raw material into a new product.

Examples of Manufacturers are:

•Condiments Manufacturer

•Fish Processor

•Poultry Processor

•Nutmeg Processor

•Cacao Processor

5.1Identification of the organization

Manufacturers/Processors need to use the Business Identification number (BID) to identify the organization they manage and then share that number with suppliers and customers. The BID is allocated by the Ministry of Health or any other designated government agency which maintains the National Business Registry for Food Operators.

Individual BIDs can be assigned to represent an organization as well as any individual trading subsidiaries.

5.2Capturing production inputs

Manufacturers may receive different types of inputs to elaborate their products. These inputs (trade items) may be raw material, live animals, ingredients or packaging material and each one of them must be traceable.

Manufacturers/Processors must retain a copy of the Sales Receipt given by the Supplier of the received trade items (or given by the Manufacturer/Processor to the Supplier in the absence thereof). The Sales Receipt copy shall have at least the following information:

•Supplier/Seller name

•Supplier/Seller contact information

•Supplier BID

•Customer name

•Customer BID

•Product Description (Brand name if applicable, including variety

•Lot number or other batch identifier of the good (i.e. harvesting date)

•Quantity and packaging information

•Date of transaction

•Origin Address: Address from where the good was delivered

•Destination Address: Address of receiving location/trading partner

•Name and contact information of the transporter

•Any other information deemed appropriate by the Competent Authority

It is recommended that the receiving information should also be recorded in a record-keeping system (paper or electronic form) and should include the following information:

•Sales Receipt number

•Product identification number (if available)

•Name of person who received the product

•Name of person who dispatched the product from the supplier

Also, received trade items must be traceable. For this reason, each Trade Item shall carry a tag or label that shows the Supplier BID and the Batch/lot number. Each time an input is received, the following information must accompany the tag or label attached to the Trade Item depending on its type (raw material, live animals, ingredients or packaging material):

5.2.1Ingredients and packaging material

Suppliers deliver their products (ingredients or packaging material) using different formats that can be containers, cases, bins, bags or bulk loads (Trade Items). Each Trade Item must be traceable. For this reason, each Trade Item carries a tag or label that shows the Supplier BID and the Batch/lot number. Each time a manufactured/processed product is received for use as an ingredient, the following information must accompany the tag or label attached to the Trade Item:

•Supplier’s Name

•Supplier BID

•Trade Item Description

•Trade Item GTIN (if available)

•Batch/Lot number

•Code for date marking as required by relevant legislation

•Quantity

5.2.2Raw material

Suppliers of Raw material normally deliver fresh products in bulk using various containers or bags to transport the Trade Items. Common examples of Trade Items include bags, cases and bins. Each Trade Item must be traceable. For this reason, each Trade Item should carry a tag or label that shows the Supplier Business ID and the Harvest date/Slaughter date. Each time a product is received for use in the process, the following information must accompany the tag or label attached to the Trade Item:

•Supplier’s BID

•Supplier’s name

•Commodity name and, where applicable, variety name

•Lot number (typically harvesting date)

•Code for date marking as required by relevant legislation

•Quantity

If the Supplier does not attach the information shown above, then the Manufacturer/Processor must assign such information prior to using the raw material in the processing line.

5.2.3Live Animals

Live animal providers deliver products in various logistic units. Each logistic unit should be individually traceable. Information used for traceability should include:

•Supplier’s name

•Supplier BID

•Accurate herd/house/pen information depending on species of the animals received

•Purchase Order Number or Live Receiving Ticket of received animals

•Date of Receipt

•Count of Animals

Live animal product lots must be traceable. This is accomplished by associating each animal lot identification number with the Product Identification and Batch/Lot Number of the output product it is used to produce.

5.3Identification of trade items and manufacturer/processor information

Each time a Trade Item is created and destined for a subsequent trading partner, it must be identified. Examples of Trade Items include trays, bags, cartons, pallets and others.

To assist customers with their subsequent traceability, Manufacturers/Processors shall attach a label to their Trade Items, in human-readable format, with all relevant traceability information. Products are labeled at the time of packaging or distribution.

Two types of Trade Items can be created by a Manufacturer/Processor:

•POS Trade Items: Trade items that go to Retail Point of Sale (POS). Normally Consumer Units.

•Non-POS Trade Items: Trade items that never go to Retail Point of Sale (POS). Normally these would comprise industrial products, logistic units, bulk products and others.

Depending on the type of Trade Item, there are different requirements to identify them and for the labels to be placed on each Trade Item.

5.3.1Identification of production batches/lots

All Manufacturers/Processors must assign a batch/lot number to products they create. The batch /lot number itself can vary from one organization to another, depending on the precision desired. For example, a batch/lot number can represent a day’s manufacturing or the product packed from an individual manufacturing line. Manufacturer batch/lot numbers must be internally linked to the original information on the ingredient or raw material used.

It is important to remember that the batch/lot number relates to the scope of products that may be implicated in a recall and needs to be considered during the assignment.

5.3.2Identification of Non POS Trade Items

Non POS Trade Items are products that are usually sold as ingredients to other Manufacturing Companies or to a Food Operator Service. These Items never cross a Retailer Point-of-Sale. To identify Non POS Trade Items, the Business ID, the Commodity name and the associated production batch/lot number are used.

5.3.2.1Guidelines to Label Non POS Trade Items

Each Non POS Trade Item should provide the following data in human-readable format:

•Manufacturers/Processor Name

•BID

•Trade Item Description

•Batch/Lot number

•Code for date marking as required by relevant legislation

•Quantity

•Additional information required by relevant legislation (e.g. weight, price, Country of Origin, etc.)

5.3.3Identification of POS Trade Items

The use of the Business Identification number (BID), the Commodity name and the associated production batch/lot number is required to identify products that go to a Point-of-Sale (POS Trade Items). Some retailers also may ask for the use of a GS1 Global Trade Item Number (GTIN) to identify trade items so the use of this standard identification in addition to the Commodity name is recommended (this is usually a minimum requirement for supermarkets, however it is not required by the Regulations Concerning the Traceability and Recall of Food Products).

5.3.3.1Global Trade Item Number

The Global Trade Item Number (GTIN) is a standardized and globally unique way to identify items traded in the supply chain. Where there is a requirement to accurately order, invoice, price or receive your product, the GTIN is the basic enabler. The GTIN provides a common language to support multiple business practices, including traceability. Where product is sold under a brand name, the brand owner is responsible for assigning the GTIN.

5.3.3.2Assignment of GTIN to the traded items that a company produces

Where product is sold under a brand name, the brand owner is responsible for assigning the GTIN. If the organization is the brand owner, the first step is to apply for a GS1 Company Prefix with a GS1 representative (normally the Bureau of Standards). If your company is not the brand owner, you must use the brand owner’s GTIN.

See Appendix 1 – Section 9.1 for more information about GTIN assignment.

5.3.3.3Guidelines for Labels on POS Trade Items:

Labels provide a means for identifying POS Trade Items to other trading partners. The label shows the product identifier (i.e. the GTIN) and associated batch/lot number in an easy-to-read, human- readable form and, if required by the customer (usually retailers), the label should also provide product information using a GS1-compliant bar code. This ensures that the POS Trade Items can be identified quickly and accurately at any POS, anywhere in the world.

Each label should provide the following data in human-readable format:

•Manufacturers/Processor Name

•BID

•Trade Item Description

•GTIN

•Batch/Lot number

•Code for date marking as required by relevant legislation

•Quantity

•Additional information required by relevant legislation (e.g. weight, price, Country of Origin, etc.)

To learn more about GS1-compliant bar codes see Appendix 1 – Section 9.1.1.

5.4Identification of cases or packs

For Manufacturers/Processors, outbound items are typically cases or packs containing multiple items (POS or Non POS Trade Items). When the company’s traceable item is a case or pack, the minimum required is to identify each traceable item with the BID and the content information (the Trade Item Description and the batch/lot number).

5.4.1Cases and packs labels

Labels provide a means to identify the product to other trading partners. The label shows the product identifier (i.e. BID and Trade Item Description) and the associated batch/lot numbers in an easy-to-read human-readable form. This ensures cases or packs can be identified at any subsequent point in the supply chain.

Labels should provide the following data in human-readable format:

•Manufacturers/Processor’ Name

•BID

•GTIN (If Product goes to a Retailer)

•Trade Item Description

•Batch/Lot number

•Best Before Date

•Content Description (e.g. 12 bottles of 120 Oz)

•Additional information if required (e.g. weight, vessel id, case serial number)

POS Trade Item Labels can also be used to identify cases or packs used to pack them, if these never go to the Retailers Point-of-Sale. However, this practice is not recommended as it can create errors. The best practice is to assign a different label, indicating the content and including a GS1- compliant barcode ITF-14.

Additional information about creating GS1-compliant bar codes is at Appendix 1 – Section 9.1.1.

5.5Traceability information to be recorded

To ensure that the traceability link is maintained, the following data must be recorded (paper form or electronic). The following represents the minimum data required to ensure traceability between the suppliers and the customers of a company.

•Identification (Trade Item Description/Commodity Name, Supplier’s Name, Supplier BID) and Batch/Lot numbers or Manufacturing Date/harvesting Date/Slaughtering Date of ingredients and raw material used

•Shipped from location identification (i.e. shipping address)

•Shipped to location identification (i.e. address of receiving location/trading partner)

•Date of dispatch/shipment

•Transporter information (name, address, telephone number, and, if available fax number and email)

•Any other information deemed appropriate by the Competent Authority.

It is also recommended that the following information should be recorded:

•Product identification number (GTIN, if available)

•Sales Receipt number

•Name of person who dispatched the product

•Name of person who received the product

Additionally, the company must retain a copy of the Sales Receipt given to the customers. The Sales Receipt copy should have a serial number and at least the following information:

•Company Name

•Contact information

•BID

•Customer’s name

•Customer BID

•Product Description (Brand name if applicable, including variety)

•Lot number or other batch identifier of the good (i.e. harvesting date)

•Quantity and packaging information

•Date of transaction

•Origin Address: Address from where the good was delivered

•Destination Address: Address of receiving location/trading partner

•Name and contact information of the transporter

•Any other information deemed appropriate by the Competent Authority

It is recommended to additionally include the following information:

•Sales Receipt number

•Product identification number (GTIN, if available)

•Price by unit or weight

•Name and signature of person who received the product

•Name and signature of person who dispatched the product from the supplier

Data attribute definitions are provided in the Glossary of Terms (Appendix 8).

5.6Data retention

All organizations are expected to maintain records that will facilitate timely and accurate traceability and support any product recalls.

Records are retained at a registered location or at another readily available location and are made available to the Competent Authority within the time limit prescribed by [rule/order] approved by the Competent Authority.

5.7Recall and withdrawal

Manufacturers/Producers need to develop a recall strategy containing the following elements:

•depth of recall, which may extend to the consumer level, the retail level, or the wholesale level;

•the contents of public notifications to be issued depending on the classification and severity of the grounds for which a recall is issued;

•public warning that is given nationwide or to affected geographical areas during urgent situations;

•effectiveness check level, which includes the method to be used for and depth recall effectiveness checks; and

•the disposal of recalled products.

It is recommended that at least one Mock Recall (simulation) should be carried out every year to test the strategy and the requirements.

5.7.1Recalls requested by the Competent Authority

For recalls requested by the Competent Authority, the following actions are undertaken by Manufacturers/Processors after the request to initiate the recall:

•stop the distribution of the product;

•withdraw the product from the market;

•notify the public, trading partners and consignees of a recall as prescribed;

•effectively and accurately inform the consumers of the reason for the recall and, if necessary, recall from consumers’ the products that have already been supplied to them (when other measures are not sufficient to guarantee food safety), following the procedures established by the Competent Authority;

•issue a press release if so directed by the Competent Authority; and

•abide by other recall requirements as may be established by the Competent Authority.

The recall is terminated when the Competent Authority determines that all reasonable efforts have been made to remove or correct the product in accordance with the recall strategy, and when it is reasonable to assume that the product subject to the recall has been removed and proper disposal or correction has been made commensurate with the degree of hazard of the recalled product. The appropriate authority will issue written notification to the Manufacturer / Processor that the recall is terminated.

5.7.2Voluntary recalls

For voluntary recalls, implementation of the following actions is recommended:

•If the Manufacturer/Processor considers or has reason to believe that a food item which it has locally distributed is not in compliance with the food safety requirements, it shall immediately initiate procedures to withdraw the food in question from the market where the food has left the immediate control of that initial food business operator and inform the competent authorities.

•Where the product may have reached the consumer, the Manufacturer/Processor shall effectively and accurately inform the consumers of the reason for its withdrawal, and if necessary, recall from consumers the products that have already been supplied to them, when other measures are not sufficient to achieve a high level of health protection.

•The Manufacturer/Processor shall immediately inform the competent authorities if it considers or has reason to believe that a food item which it has placed on the market may be injurious to human health. Also, it shall inform the competent authorities of the action taken to prevent risks to the final consumer.

5.8Business scenarios for manufacturers/processors

5.8.1Scenario 1: Condiment manufacturer using ingredients from suppliers and selling products to retail

5.8.1.1Description of the process:

The process starts when the ingredients, raw material and packaging material are received in the Manufacturer’s Facilities and stored, waiting to be used for preparing a condiment. The ingredients and packaging material are received from multiple suppliers (manufacturing companies) and raw material (mainly pepper) from distributors, traders or local farmers. All of the ingredients, packaging materials and raw materials contain multiple batch/lot numbers.

The Condiment Manufacturer prepares the final product using multiple ingredients and raw materials, each with different batch/lot numbers into a packaged manufactured product where a product name, product identification number (GTIN) and batch/lot number is assigned.

After the final product is prepared and packaged, these are sold and distributed to final customers, retailers or exported.

5.8.1.2Description of the traceability process:

•Receiving process

When receiving, the manufacturer must verify that all the received products are properly identified with a label (or tag) showing the following information:

-Supplier Name

-Supplier Business Identification Number

-Product Description

-Batch number

-Quantity

The manufacturer must keep a record of the information of all the products received using the sales receipt given by the supplier (one copy retained by the manufacturer, one copy remains with the supplier) (see Appendix 2 – Section 10.4.1). The following information is recorded:

-Supplier Name, Business Identification Number and Delivery Address

-Product received

-Batch number

-Receiving Date (dd/mm/yy)

-Quantity

-Manufacturer Name, Business ID Number and Receiving Address

Note: If it is not possible to obtain a Sales Receipt from the Supplier with the required traceability information, then the supermarket must record the required information using the Input Control Form (see Appendix 2 – Section 10.4.2) and staple this together with the invoice given by the supplier.

•Processing

When manufacturing a product, the Manufacturing Process form (see Appendix 2 – Section 10.4.4) is used to record the following manufacturing information:

-Product Description (in each final format)

-GTIN (if applicable)

-Quantity (for each product)

-Manufacturing Date (dd/mm/yy)

-Batch Number

-Ingredients/Raw Material applied during the process (Product code, Product Name, Supplier BID, Batch/Lot, Quantity)

-Packaging material used (Product, Supplier BID, Batch/Lot, Quantity)

All the final products are labeled with the Manufacturer’s name, Business Identification Number (BID), Product Description, Product Code (GTIN if applicable) and Batch number.

•Delivery process

When final products are dispatched, the manufacturer must issue a sales receipt (one copy given to the customer, one copy retained by the manufacturer) (see Appendix 2 – Section 10.4.3). The information to record in the sales receipt is as follows:

-Manufacturer Name, Business Identification Number and Delivery Address

-Product Description

-Batch number or Harvesting Date (dd/mm/yy)

-Quantity

-Customer name, Business ID Number and Receiving Address

5.8.2Scenario 2: Nutmeg processor using raw material from growers

5.8.2.1Description of the process:

The Drying process is divided in two aspects. The first one consists of drying the nutmeg in drying shelves. The second part consists of packing the final product into jute bags.

The process starts when the farmers in the parish deliver their nutmegs to the drying facility. Upon receipt, the nutmeg is separated into different products and each one is mixed in one batch and placed on a drying shelf (different for each product) for a period of time. At the end of this period, the shelf is closed and the newly-received nutmegs are placed on a new shelf.

At the end of the drying process, the dried products are sent to be processed, selected/sorted and packed in jute bags of 62.5 Kg. each.

5.8.2.2Description of the traceability process:

•Receiving process

Nutmegs may be received directly from farmers in the drying station or may be received in one of the receiving stations and then transported to the closest drying station.

When farmers deliver their nutmegs to the receiving stations a sales receipt (see Appendix 2 – Section 10.5.1) is issued (one copy remains with the Processor, one copy with the farmer). The information in the Sales Receipt is the following:

-Farmer Name

-Farm ID

-Farm/Plot Address

-Products received

-Receiving Date (dd/mm/yy)

-Plot (Origin)

-Total Weight (Kg)

The Sales Receipt number is recorded in a Control Summary Form (see Appendix 2 – Section 10.5.3). During the day, all the nutmegs received from all the farmers are mixed together. At the end of the day, all the nutmegs received during the day are sent to the closest drying station. Every time the nutmegs are delivered, a Delivery Advice is created and the Delivery Advice number is also recorded in the Control Summary Form for that day, grouping all the Sales Receipt numbers.

When the drying station receives the nutmeg (from farmers or from other receiving stations), the receiving information is recorded in a Control Summary Form (see Appendix 2 – Section 10.5.3). The information recorded is the same shown above. If the nutmeg is received directly from the farmers, then a Sales Receipt is issued and the Sales Receipt number is recorded in the Form, but if the nutmeg is received from another station, the Delivery Advice number is recorded in the Form. All the nutmegs received are then stored in a shelf identified with a number. More than one shelf could be used.

At the end of the day the completed shelves are closed and the number is recorded in the Control Summary Form (see Appendix 2 – Section 10.5.4). The non-completed shelf is mixed with the receiving nutmegs of the following day. Then the Batch is the end date of the shelf.

•Processing

When starting the drying process, the Drying Process Form (see Appendix 2 – Section 10.5.4) should be used to record information. The information to record is as follows:

-Product Description

-Batch Number

-Start Date

-End Date

-Shelves used

-Product/Ingredients applied to the process (Product, Supplier BID, Batch, Date, Quantity.)

Then, at the end of the drying process, the Drying/Packing form (see Appendix 2 – Section 10.5.5) is used to record the following processing information:

-Product Description

-Packing Date (dd/mm/yy)

-Drying – Initial Date (dd/mm/yy)

-Batch Number (Packing Date + Drying Plant)

-Quantity (Number of bags)

-Total Weight (Kg)

-Shelves used

-Product/Ingredients applied to the process (Product, Supplier BID, Batch, Date, Quantity.)

-Packaging material used (Product, Supplier BID, Batch, Date, Quantity.)

All the jute bags with the respective dried product are labeled with the company name, Facility name, Business Identification Number (BID), Product Description and Batch number.

•Delivery Process

When a jute bag is dispatched, a sales receipt (see Appendix 2 – Section 10.5.6) is issued (one copy retained by the drying facility, one copy given to the customer).

5.8.3Scenario 3: Cocoa Processor using raw material from growers

5.8.3.1Description of the process:

The Drying process is an “all in all out” process. All the farmers in a parish deliver their cocoa seed to the drying facility approximately every 15 days. The drying facility receives the cocoa seeds from almost 100% of the farmers in that parish every time they start a new drying process.

When the seeds are received, all are mixed in one batch and dropped into 1 to 8 drying boxes (depending on the amount). At the end of the drying process, the dried seeds are packed in jute bags of 62.5 Kg. each.

5.8.3.2Description of the traceability process:

•Receiving Process

When receiving, the drying facility will record the information of all the farmers involved. The information to record is as follows:

•Farmer Name

•Farm ID

•Farm/Plot Address

•Product received

•Receiving Date (dd/mm/yy)

•Plot (Origin)

•Total Weight (Kg)

This information is recorded on a Receiving Form (see Appendix 2 – Section 10.6.3) and a sales receipt (see Appendix 2 – Section 10.6.1) is issued (one copy retained by the drying facility, one copy given to the farmer).

•Processing

When starting the drying process, the Drying/Packing form (see Appendix 2 – Section 10.6.4) is used to record the following processing information:

-Product Description

-Packing Date (dd/mm/yy)

-Drying - Initial Date (dd/mm/yy)

-Batch Number (Packing Date + Drying Plant)

-Quantity (Number of bags)

-Total Weight (Kg)

-Boxes used

-Product/Ingredients applied to the process (Product, Supplier BID, Batch, Date, Quantity.)

-Packaging material used (Product, Supplier BID, Batch, Date, Quantity.)

At the end of the process, all the jute bags with dried cocoa seeds are labeled with the company name, Facility name, Business Identification Number (BID), Product Description and Batch number.

•Delivery process

When a jute bag is dispatched, a sales receipt (see Appendix 2 – Section 10.6.2) is issued (one copy retained by the drying facility, one copy given to the customer).

5.8.4Scenario 4: Fish Processor using raw material from vessels

5.8.4.1Description of the Process:

The fish is received from different vessels in the jetty. Upon receiving, it is weighed, tested and dropped into plastic bins identified with the vessels ID and the receiving date (when the fish is large, a tag with the identification is inserted into the fish). The vessels deliver the fish cooled, beheaded, gutted and bled. The Processing Plant carries out the following activities after receiving the fish.

•Temperature controlling

•Sorting (weighted, sized and quality tested)

•Cooling

•Packing

•Storing

•Dispatch

5.8.4.2Description of the traceability process:

•Receiving process

Upon receiving the commodity, the Processing Plant records the following information:

-Fisherman Name

-Vessel ID

-Jetty (Address)

-Species

-Receiving Date (dd/mm/yy)

-Quantity

This information is recorded and a sales receipt (see Appendix 2 – Section 10.7.1) is issued (one copy to the Fish Processor, one copy to the fisherman).

The Fish Processor also must keep a record with the information of all the ingredients and packaging material received using the sales receipt given by the supplier (one copy given to the Fish Processor, one copy retained by the supplier). The information to be recorded in the sales receipt is as follows:

-Supplier Name, Business Identification Number and Delivery Address

-Product received

-Batch/Lot number

-Receiving Date (dd/mm/yy)

-Quantity

-Fish Processor Name, Business ID Number and Receiving Address

Note: If it is not possible to obtain a Sales Receipt from the supplier, then the Fish Processor must record the required information using the Input Control Form (see Appendix 2 – Section 10.7.3) and staple this together with the invoice given by the supplier using the sample given.

•Processing

When processing the fish, the traceability information is recorded using the Packing form (see Appendix 2 – Section 10.7.4). The information to record is the following:

-Product Description

-Process/Packing Date (dd/mm/yy)

-Batch Number

-Quantity (Number of bags)

-Serial Numbers (only for large fish)

-Raw material/Ingredients/inputs used during the process (Product code, Description, Supplier BID, Batch, Quantity). This must include the fish to process (In this case, the Batch Number could be the Vessel’s Name + Receiving Date, i.e. BM22082015 or just a simple code to reference by records the vessel and the receiving date).

-Packaging material used (Product code, Product name, Supplier BID, Batch, Date, Quantity)

All the bags or cases (trade items) with the respective product must be labeled or marked with the following information:

-Fish Processor name

-Business Identification Number (BID)

-Product Description

-Batch number or Packing Date

•Delivery process

When a trade item is dispatched, a sales receipt (see Appendix 2 – Section 10.7.2) is issued (one copy retained by the SFA, one copy given to the customer). The information to record in the sales receipt is as follows:

-Fish Processor Name, Business Identification Number and Delivery Address

-Product Description

-Batch number or Packing Date (dd/mm/yy)

-Quantity

-Customer name, Business ID Number and Receiving Address

5.8.5Scenario 5: Poultry Processor using raw material from farms and sold locally

5.8.5.1Description of the process for poultry processors:

The process starts when the birds are received alive in the processing facility from different farms and pens. The following activities are performed:

•Slaughtering

•Processing

•Packing

•Storing

•Selling

The processing facility receives packaging material and in some cases can receive ingredients (for seasoning) from multiple suppliers (manufacturing companies). All the packaging material and ingredients may contain multiple batch/lot numbers.

The final product can be a whole bird or parts of it. The packaged product contains a label with the Processor’s name, product description and batch/lot number (i.e. processing date).

After the final product is prepared and packaged, these are sold and distributed to final customers.

5.8.5.2Description of the traceability process for poultry processors:

•Receiving birds and inputs

When receiving birds, the processor must record the following information of the received commodity:

-Supplier Name, Business Identification Number and Address

-Species received

-Pen Identification

-Receiving Date (dd/mm/yy)

-Quantity

-Farmer name, address and Business ID Number

To record the information, a sales receipt is issued (see Appendix 2 – Section 10.8.1). One copy is retained by the processor, one copy remains with the supplier, even if the company is vertically integrated.

When receiving ingredients or packaging material, the processor must keep a record of the information on all the received inputs using the sales receipt given by the supplier (one copy given to the processor, one copy retained by the supplier). The information to be recorded in the sales receipt is as follows:

-Supplier Name, Business Identification Number and Address

-Receiving Date (dd/mm/yy)

-Product Description

-Batch/lot number

-Quantity

-Processor name, address and Business ID Number

Note: If the input Supplier does not give a Sales Receipt with all the required information, then the processor can register the required information using the sample Input Control Form (see Appendix 2 – Section 10.8.2) and staple this together with the sales receipt/invoice given by the input Supplier.

•Processing

When processing, the Packing Process form (see Appendix 2 – Section 10.8.4) should be used to record the following manufacturing information:

-Product Description (in each final format)

-Quantity (for each product)

-Slaughtering/Processing Date (dd/mm/yy)

-Batch Number

-Raw Material used during the process (Description, Supplier BID, Pen/Batch, Receiving Date, Quantity)

-Ingredients used (Product Code, Product Name, Supplier BID, Batch/lot, Quantity)

-Packaging material used (Product Code, Product Name, Supplier BID, Batch/Lot, Quantity)

All the final products are labeled with a human-readable tag or label (see image). The tag or label generally must contain the following information:

-Processor’s name

-Business Identification Number (BID)

-Product Description

-GTIN (if applicable)

-Packing date

-Batch number

Note: Processors do not need to assign a label when delivering if they immediately transfer their products to the customer’s bins or containers when the customer receives the product. In this case it is the customer who is required to assign a label to each bin or container in order to control the origin of the received products.

•Delivery process

When products are delivered, a sales receipt (see Appendix 2 – Section 10.8.3) is issued (one copy is given to the customer, one copy is retained by the processor). The information to record in the sales receipt is as follows:

-Processor Name, Business Identification Number and Delivery Address

-Product Description

-Packing Date

-Batch number

-Quantity

-Receiving facility name, address and Supermarket Business ID Number

6    IMPLEMENTATION GUIDELINE FOR RETAIL STORES

This section is intended for Retail Stores where the traceable item is usually a Point-of-Sale (POS) Trade Item (Consumer unit), although sometimes it may also be a Non POS Trade Item (logistic unit).

Examples of Retail Stores are:

•Supermarket Stores

•Grocery Stores

•Grocery Chains

6.1Unique identification of the organization

Retail Stores need to use the Business Identification number to identify the organization they manage and then share that number with suppliers and customers. The Business ID is allocated by the Ministry of Health or any other designated government agency which maintains the National Business Registry for Food Operators.

Individual BIDs can be assigned to represent an organization as well as any individual trading subsidiaries.

6.2Capturing inputs

Retail stores must capture traceability information from the products (Consumer units) sent by their suppliers. These products are identified using a Global Trade Item Number (GTIN). The assignment of GTINs for each product traded (i.e. all product configurations) is the responsibility of the brand owner and must be recorded in the Retailer’s internal systems prior to the product being traded. Use of the GTIN ensures unique product identification across all of a supplier’s product configurations and uniqueness across all sources of supply.

When the trading relationship requires that the inbound product is traceable, this is accomplished by associating each GTIN with its batch/lot number. GTIN and batch/lot information is displayed on individual case labels.

Retail stores may also need to capture information about outbound shipments to stores; these are typically bags or cases. The bags and cases are identified at the time that they are created by the supplier and are individually identified using GTIN and batch/lot number. This number is assigned by the supplier/shipper or the retailer and appears on individual labels. The label provides a reference that can be traced to the original source. Each order that is shipped to a store should have the linkage between the order, GTIN, batch/lot number, and quantity shipped. The retailer may also create new logistics units and this information must be captured as well.

To enable traceability, retail stores must also maintain records of other product inputs (e.g. packaging material) for their own use. This information is equally critical to the company’s body of internal traceability information.

6.3Identification of trade items

Normally retailers need to cut and re-pack fresh produce, fish, meat, poultry, or other products that arrive from their suppliers in large sizes or in bulk (e.g. rice, flour, sugar, beans). Each time there is a need to identify these products (intended to pass through a Point-of-Sale), it is necessary to use GTIN and associated production batch/lot number. The batch/lot number is determined by the trading party that created the individual trade item.

What is a Global Trade Item Number?

A Global Trade Item Number (GTIN) is a standardized and globally unique way to identify items traded in the supply chain. Where there is a requirement to accurately order, invoice, price or receive your product, then the GTIN is the basic enabler. The GTIN provides a common language to support multiple business practices, including traceability.

How is a GTIN assigned to the traded items that my company produces?

Where product is sold under a brand name, the brand owner is responsible for assigning the GTIN. If your company is the brand owner, the first step is to approach your local GS1 representative and apply for a Company Prefix. The Company Prefix is globally unique for each organization and it is used to create the GTINs assigned to the organization’s trade items. Your company then assigns a GTIN to each one of your products and every packaging configuration. Your company is responsible for communicating GTIN’s to your packers.

If the retailer is not the brand owner, then it must use the brand owner’s GTIN. When the brand is owned by the supplier, the supplier is responsible for assigning GTINs to each configuration of the traded item.

6.3.1.1Guidelines for Labels on POS Trade Items:

Labels provide a means to identify POS Trade Items to other trading partners. The label shows the product identifier (i.e. the GTIN) and the associated batch/lot number in an easy-to-read human-readable form and, as a best practice, provides product information using a GS1-compliant bar code. This ensures POS Trade Items can be identified quickly and accurately at any POS.

Each consumer unit label should provide the following data in human-readable format:

•Retailers’ Name

•BID

•Trade Item Description

•GTIN

•Batch/Lot number

•Code for date marking as required by relevant legislation

•Quantity

•Additional information required by relevant legislation (e.g. weight, price, Country of Origin, etc.)

For information about creating GS1-compliant barcodes, see Appendix 1 – Section 9.1.1

6.4Traceability information to be recorded

To ensure that the traceability link is maintained, the following data must be recorded (paper form or electronic). The following represents the minimum data required to ensure traceability with the company’s source of supply.

•When the supplier’s product (trade item) is the traceable item:

○Supplier’s name

○Supplier BID

○Trade item identifier (GTIN)

○Trade item description

○Batch/Lot number

○Trade item quantity and unit of measure

○Shipped from location identification (i.e. shipping address)

○Shipped to location identification (i.e. address of receiving location/trading partner)

○Date of shipment

○Date of receipt

○Transporter information (name, address, telephone number, and, if available fax number and email)

○Any other information deemed appropriate by the Competent Authority

•When the retailer’s product (trade item) is the traceable item (Product re-packaged by the retailer):

○Retailer’s name

○Retailer BID

○Trade item identifier (GTIN)

○Trade item description

○Batch/Lot number

○Trade item quantity and unit of measure

○Shipped from location identification (i.e. shipping address)

○Shipped to location identification (i.e. address of receiving location/trading partner)

○Date of shipment

○Date of receipt

○Transporter information (name, address, telephone number, and, if available fax number and email)

○Any other information deemed appropriate by the Competent Authority

It is recommended that the following information is also recorded:

•Sales Receipt number

•Name of person who dispatched the product

•Name of person who received the product

Data attribute definitions are provided in the Glossary of Terms (Section 8).

6.5Data retention

All organizations are expected to maintain records that will facilitate timely and accurate traceability and support any product recalls.

Records are retained at a registered location or at another readily available location and made available to the Competent Authority within the time limit prescribed by [rule/order] approved by the Competent Authority.

6.6Recall and withdrawal

Retailers need to develop a recall strategy containing the following elements:

•depth of recall, which may extend to the consumer level, the retail level, or the wholesale level;

•the contents of public notifications to be issued depending on the classification and severity of the grounds for which a recall is issued;

•public warning that is given nationwide or to affected geographical areas during urgent situations;

•effectiveness check level, which includes the method to be used for and depth recall effectiveness checks; and

•the disposal of recalled products.

It is recommended that at least one Mock Recall (simulation) is carried out every year to test the strategy and the requirements.

6.6.1Recalls requested by the Competent Authority

For recalls requested by Competent Authority, the following actions are undertaken by Retailer after the request to initiate the recall:

•stop the distribution of the product;

•withdraw the product from the market;

•notify the public, trading partners and consignees of a recall as prescribed;

•effectively and accurately inform the consumers of the reason for the recall and, if necessary, recall from consumers the products that have already been supplied to them (when other measures are not sufficient to guarantee food safety), following the procedures established by the Competent Authority;

•issue a press release if so directed by the Competent Authority; and

•abide by other recall requirements as may be established by the Competent Authority.

The recall is terminated when the Competent Authority determines that all reasonable efforts have been made to remove or correct the product in accordance with the recall strategy, and when it is reasonable to assume that the product subject to the recall has been removed and proper disposal or correction has been made commensurate with the degree of hazard of the recalled product. The appropriate authority issues to the Retailer written notification that the recall is terminated.

6.6.2Voluntary recalls

For voluntary recalls, implementation of the following actions is recommended:

•If the Retailer considers or has reason to believe that a food which it has locally distributed is not in compliance with the food safety requirements, it shall immediately initiate procedures to withdraw the food in question from the market where the food has left the immediate control of that initial food business operator and inform the competent authorities.

•Where the product may have reached the consumer, the Retailer shall effectively and accurately inform the consumers of the reason for its withdrawal, and if necessary, recall from consumer the products that have already been supplied to them, when other measures are not sufficient to achieve a high level of health protection.

•The Retailer shall immediately inform the competent authorities if it considers or has reason to believe that a food which it has placed on the market may be injurious to human health. Also, it shall inform the competent authorities of the action taken to prevent risks to the final consumer.

6.7Business scenarios for retail stores

6.7.1Receiving produce / products at retailer’s produce packing center

6.7.1.1Description of the process for supermarkets:

The process starts when the produce and packaging material are received at the Supermarket. The packaging material may be received from multiple suppliers (manufacturing companies) and the produce from local farmers or imported. All of the packaging material and produce may contain multiple batch/lot numbers.

The Supermarket prepares a final product to be displayed in the store. There are three alternatives:

1.Send the product directly to the store without any process

2.Repack the product that comes from the processor

3.Prepare a new final product with multiple products and batch/lot numbers into a new package.

In the first case, there is no need to apply a label, as the products are to be displayed in bulk in the store.

In the second and third cases, a label with the product name/description, product identification number (GTIN if applicable) and batch/lot number is assigned.

After the final products are prepared, these are sent for display in the store.

6.7.1.2Description of the traceability process for Supermarkets:

•Receiving Process

When receiving, the supermarket must verify that all the received products are properly identified with a label (or tag) showing the following information:

-Supplier Name

-Supplier BID

-Commodity Description

-Harvesting Date (dd/mm/yy)

-Quantity

Note: Labels must be attached by the farmer at origin or by the supermarket when receiving and transferring the products to their own bins or containers.

The supermarket must keep a record with the information of all the products received using the sales receipt given by the supplier (one copy retained by the supermarket, one copy remains with the supplier) (see Appendix 2 – Section 10.1.3). The information to be recorded in the sales receipt is as follows:

-Supplier Name, BID and Delivery Address

-Product received

-Batch number or Harvesting Date (dd/mm/yy)

-Receiving Date (dd/mm/yy)

-Quantity

-Receiving facility Name and Receiving Address and Supermarket BID

Note: If it is not possible to obtain a Sales Receipt from the Supplier with the required traceability information, then the supermarket must record the required information using the Input Control Form (see Appendix 2 – Section 10.9.1) and staple this together with the invoice given by the supplier.

The supermarket also must keep a record with the information of all the packaging material received using the sales receipt given by the supplier (one copy given to the supermarket, one copy retained by the supplier). The information to be recorded in the sales receipt is as follows:

-Supplier Name, BID and Delivery Address

-Product received

-Batch/Lot number

-Receiving Date (dd/mm/yy)

-Quantity

-Receiving facility Name, Address and Supermarket BID

Note: If it is not possible to obtain a Sales Receipt from the packaging material supplier, then the supermarket must record the required information using the Input Control Form (see Appendix 2 – Section 10.9.1) and staple this together with the invoice given by the supplier using the sample given.

•Processing and Display in Store

When preparing a final product to be displayed in the store, the following information should be recorded in the Processing / Packing form (see Appendix 2 – Section 10.9.2):

-Product Description

-GTIN (if applicable)

-Batch Number

-Packing Date

-Quantity

-Raw Material used during the process (Product code, Product Name, Supplier BID, Batch/Lot, Quantity)

-Packaging material used (Product code, Product Name, Supplier BID, Batch/Lot, Quantity)

All the final products are labeled with the Supermarket name, Business Identification Number (BID), Product Description, Product Code (GTIN if applicable) and Batch number.

If the received products are sent to be displayed in bulk in the store (without any processing), the supermarket must know, via records, what they have displayed at the store. The Processing / Packing form can be used for this purpose (see Appendix 2 – Section 10.9.2). The information to record is as follows:

-Product Description

-GTIN (if applicable)

-Batch Number

-Produce displayed (Product code, Product Name, Supplier BID, Batch/Lot, Quantity). If a product mixed from more than one farmer, then the information of the product in the mix from each farmer must be recorded (See example below).

7    IMPLEMENTATION GUIDELINE FOR FOODSERVICE OPERATORS

This section is intended for Foodservice Operators. Examples of Foodservice Operators are:

•Restaurants

•Hotel Restaurants

•Fast Food Restaurant chains

7.1Identification of the organization

Foodservice Operators need to use the Business Identification number (BID) to identify the organization they manage and then share that number with suppliers. The Business ID is allocated by the Ministry of Health or any other designated government agency which maintains the National Business Registry for Food Operators.

Individual BIDs can be assigned to represent your organization as well as any individual trading subsidiaries.

7.2Capturing inputs

Foodservice operators must capture product information from their supplier companies. Depending on the supplier, there are different ways these products are identified. Some items are received with identification (Global Trade Item Number (GTIN)), while other items received are identified via the Suppliers Business ID and the Commodity name or Trade Item Description.

When the trading relationship requires that the inbound product is traceable, this is accomplished by associating the identification of each product (GTIN or Supplier Business ID plus Commodity or Trade Item name) with its batch/lot number. Product identification and batch/lot information is displayed on individual case labels.

Foodservice operators may also need to capture information about outbound shipments to locations; these are typically cases. The cases are identified at the time that they are created by the supplier and are individually identified using product identification (GTIN or Supplier BID plus Commodity or Trade Item name) and batch/lot number. This number is assigned by the supplier/shipper or the foodservice operator and appears on individual case labels. The case label provides a reference that can be traced to the original source. Each order that is shipped to a location should have the linkage between the order, Product identification, batch/lot number, and quantity shipped.

Foodservice operators do not need to identify or label products.

7.3Traceability information to be recorded

To ensure that the traceability link is maintained, the following data must be collected and recorded. The following represents the minimum data required to ensure traceability with a company’s source of supply.

•When the supplier’s product (trade item) is the traceable item:

○Supplier’s name

○Supplier BID

○Trade item description

○Batch/Lot number

○Trade item quantity and unit of measure

○Shipped from location identification (i.e. shipping address)

○Shipped to location identification (i.e. address of receiving location/trading partner)

○Date of shipment

○Date of receipt

○Transporter information (name, address, telephone number, and, if available fax number and email)

○Any other information deemed appropriate by the Competent Authority

It is also recommended that the following information is recorded:

•Product identification number (GTIN, if available)

•Sales Receipt number

•Name of person who dispatched the product

•Name of person who received the product

Data attribute definitions are provided in the Glossary of Terms (Appendix 8).

7.4Data retention

All organizations are expected to maintain records that will facilitate timely and accurate traceability and support any product recalls.

Records are retained at a registered location or at another readily available location and shall make the records available to the Competent Authority within the time limit prescribed by [rule/order] approved by the Competent Authority.

7.5Recall and withdrawal

Foodservice Operators need to develop a recall strategy for foods stored in their warehouses containing the following elements:

•depth of recall, which may extend to the consumer level;

•the contents of public notifications to be issued depending on the classification and severity of the grounds for which a recall is issued;

•public warning that is given nationwide or to affected geographical areas during urgent situations;

•effectiveness check level, which includes the method to be used for and depth recall effectiveness checks; and

•the disposal of recalled products.

It is recommended that at least one Mock Recall (simulation) is carried out every year to test the strategy and the requirements.

7.5.1Recalls requested by the Competent Authority

For recalls requested by Competent Authority, the following actions are undertaken by Foodservice Operators after the request to initiate the recall:

•stop the distribution of the product;

•withdraw the product from the facilities;

•notify trading partners of the prescribed recall;

•abide by other recall requirements as may be established by the Competent Authority.

The recall is terminated when the Competent Authority determines that all reasonable efforts have been made to remove or correct the product in accordance with the recall strategy, and when it is reasonable to assume that the product subject to the recall has been removed and proper disposal or correction has been made commensurate with the degree of hazard of the recalled product. The appropriate authority will issue written notification to the Foodservice Operator that the recall is terminated.

7.5.2Voluntary recalls

For voluntary recalls, implementation of the following actions is recommended:

•If the Foodservice Operator considers or has reason to believe that a food item which it has locally distributed is not in compliance with the food safety requirements, it shall immediately initiate procedures to withdraw the food in question from the market where the food has left the immediate control of that initial food business operator and inform the competent authorities.

•Where the product may have reached the consumer, the Foodservice Operator shall effectively and accurately inform the consumers of the reason for its withdrawal, and if necessary, recall from consumers the products already supplied to them when other measures are not sufficient to achieve a high level of health protection.

•The Foodservice Operator shall immediately inform the competent authorities if it considers or has reason to believe that the food which it has placed on the market may be injurious to human health. Also, it shall inform the competent authorities of the action taken to prevent risks to the final consumer.

7.6Business scenarios for foodservice operators / retail stores

7.6.1Scenario 1: Restaurant chain receives manufactured product direct-to-store

7.6.1.1Description of the process:

Old Town Restaurants is a small regional fast-food restaurant operator. Old Town does not operate a central receiving facility and requires that all suppliers deliver products direct to each of the Old Town’s restaurant locations.

Clark Wholesalers is a large distributor of manufactured products mainly imported from the United States of America (USA), where products from different brands are consolidated, also including some from local manufacturers. All the products distributed by Clark Wholesalers are identified with a GTIN and a lot number.

On a weekly basis, Old Town Restaurants issues a purchase order to Clark Wholesalers which, in turn deliver products to the restaurant locations within 24-48 hours.

Clark Wholesalers trace the outbound movement of product and the logistic units used to ship them.

7.6.1.2Description of the traceability process:

•Old Town communicates a purchase order by email to Clark Wholesalers identifying the product (GTIN) and quantity required as well as the restaurant(s) for distribution.

•Clark Wholesalers processes the order and builds a single shipment with multiple delivery (drop) locations. The product is aggregated and palletized by delivery location.

•As all the products distributed by Clark Wholesalers are identified with a GTIN and a lot number, each product case displays the GTIN and batch/lot number in bar coded form.

•At the time of pick-up, each product (case) GTIN is scanned (i.e. both the GTIN and batch/lot number) and later associated with a specific customer delivery location.

•A pallet is built for each Old Town delivery location. Each pallet is designated with a Serial number (correlative number).

•A pallet label is attached to each outbound pallet showing the Serial number as well as:

○Shipper information (Company Business ID, shipped from address)

○Consignee information (Company Business ID, shipped to address)

•All pallet information is linked to a master shipment record and to a “sales receipt”.

•Clark Wholesalers also sends a packing slip transaction document, which defines the contents of the shipment destined for each of Old Town’s restaurant locations. This enables Old Town to reconcile the inbound shipment to outstanding purchase orders and to record all inbound GTINs and their batch/lot numbers.

•As each pallet is delivered to its Old Town store location, the pallet Serial number is recorded. This enables Old Town to confirm delivery and to update store inventory records.

•In the event of a product recall, Old Town’s records are able to verify the product batches that were delivered to any one of their restaurant locations.

7.6.2Scenario 2: Hotel restaurant receives fresh produce product direct-to-store

7.6.2.1Description of the Process:

Treasure Hotels is a luxury international hotel chain on an island, operating a single large, central facility for all the restaurants inside the hotel. Treasure Hotels requires that all suppliers deliver products direct to the central receiving facility.

Always Fresh Produce is a distributor of fresh fruit and vegetables that markets produce under the brand names of Major Packers and under their own “Always Fresh” brand.

Each week, Treasure Hotels issues a purchase order to Always Fresh which, in turn delivers the order to the central receiving facility location within 24-48 hours.

Always Fresh traces the outbound movement of product and the logistic units used to ship them.

7.6.2.2Description of the Traceability Process:

•Treasure communicates a purchase order by email to Clark Wholesalers identifying the product name and quantity required.

•Always Fresh processes the order and prepares a single shipment.

•Products distributed by Always Fresh are packaged in cases, all identified and labeled with the Product Identification (Business ID and Commodity name) and a batch/lot number.

•At the time of pick-up, each product (case) is recorded (i.e. both Product Identification and batch/lot number) and later associated with the specific customer delivery location.

•The information of every case (Product Identification and Batch/lot number) is linked to a master shipment record and to a “sales receipt”.

•Always Fresh also sends a packing slip transaction document to Treasure. This document defines the contents of the shipment destined for Treasure and enables Treasure to reconcile the inbound shipment to outstanding purchase orders and to record all inbound products and their batch/lot numbers.

•As each case is delivered to the central receiving location at Treasure, the case label information is recorded. This enables Treasure to confirm delivery and to update hotel inventory records.

•In the event of a product recall, Treasure’s records are able to verify the product batches that were delivered to their central receiving location.

8    GLOSSARY

The terms presented below are drawn mainly from the Draft Food Traceability and Recall Legislation Recommendations[18], from the GS1 Global Traceability Standard[19]and finally from the ISO 22005:2007[20].

9    APPENDIX 1: GLOBAL TRADE ITEM NUMBER (GTIN)

9.1GTIN assignment further explained

The Global Trade Item Number (GTIN) uniquely identifies trade items, including both products and services that are sold, delivered, and invoiced at any point in the supply chain. GTINs provide unique identification worldwide. The GTIN is most frequently encountered at Point-of-Sale and on cases and pallets of products in a distribution/warehouse environment. It is normally requested by retailers.

Key Benefits of the GTIN

•Facilitates the global flow of trade items (products and services) and associated information used in electronic commerce

•Uniquely identifies trade items at all levels of packaging (item, case, and pallet)

•Delivers trade item data in a consistent format and structure

•Simplifies supply chain management

•Employs the globally accepted GS1 System, in which the language is standardized, understood and used by multiple industries

Why is the GTIN Useful?

Uniqueness: The GTIN uniquely identifies an item. The rules for assigning GTINs ensure that every variation of an item (product or service) is allocated a single reference number that is globally unique.

Non-significance: The GTIN numbering structure does not contain any meaningful information in itself. A GTIN is a simple pointer to database information that can be directly used in any company and in any country.

Multi-sector: GTINs are unique across all business sectors. This means that items such as a health-care product, a grocery product, or an apparel product are all identified in a compatible manner.

International: GTINs are unique worldwide. A GTIN can be assigned anywhere in the world and can be used anywhere in the world.

Data Integrity: The Check Digit ensures the integrity of data passing through the system.

Source Numbering: The GTIN is assigned by the brand owner of the product. Once assigned, all trading partners and internal users can use the GTIN. The same GTIN can be used to identify a series of identical items.

Automatic Data Capture: One of the key benefits of the GTIN is that it can be encoded in many automatic data capture technologies (such as a bar code or electronic product code used in Radio Frequency Identification (RFID) tags). Machine reading allows the information flow to be linked to the physical flow of trade items through the supply chain.

GTINs are typically 8 digits, 12 digits, 13 digits, or 14 digits in length. It is recommended that a GTIN be represented in software applications as 14 digits by right justifying and zero filling left, as appropriate.

GTINs can be represented in a bar code and each provides unique numbers when right justified and used in a 14-digit database field:

•GTIN-8

○Seven digits containing a Company Prefix and the Item Reference Digits.

○One digit representing the Check Digit

•GTIN-12

○Eleven digits containing a Company Prefix and the Item Reference assigned by your company

○One digit representing the Check Digit

•GTIN-13

○Twelve digits containing a Company Prefix and the Item Reference assigned by your company

○One digit representing the Check Digit

•GTIN-14

○When constructing a GTIN 14 for the identification of packaging, such as cases for fixed weight product, the first digit (with a value of 1 through 8) is an indicator digit. The next 12 digits reflect the GTIN on the consumer item in the case. The last digit is a recalculated check digit.

○Twelve digits the Company Prefix and the Item Reference assigned by the company

○One digit representing the Check Digit

Company Prefix - The globally unique number assigned to a company by GS1 through a local representative (Normally the Bureau of Standards).

Item Reference - The number assigned by a holder of the Company Prefix to uniquely identify a trade item. The Item Reference varies in length as a function of the Company Prefix length.

Check Digit - A calculated one-digit number used to ensure data integrity.

The following illustrates the uses of a GTIN in a bar code

There are seven variations of the DataBar symbology. The example shown is the most common one related to the identification of loose produce such as apples, bananas, etc. The variations GS1 DataBar Expanded and GS1 DataBar Expanded Stacked can encode additional information such as net weight or price.

9.1.1How to create a quality gs1-compliant bar code

Use of Application Identifiers (AIs):

The GS1-128 symbology allows for the encoding of secondary information. This is done through the use of application identifiers. In the example below the application identifier is encased in parentheses. The identifier (01) indicates that what follows is a GTIN. The identifier (17) indicates that what follows is the expiry date expressed in the format YYMMDD. The identifier (10) indicates the batch/lot number.

Note that the parentheses are not encoded in the bar code.

For complete technical specifications on the use of GS1 bar code symbologies consult the GS1 General Specifications or contact a GS1 representative

Figure 18: illustrates how the use of GS1 Application Identifiers (AI’s) can be applied to product and logistic unit labels across the supply chain.

Ten steps to bar code implementation:

The following provides a 10-step model to ensuring that a Company produces quality bar codes. Additional assistance can be found by contacting the package/printer supplier or a GS1 representative.

•Step 1: Obtain a Company Prefix

•Step 2: Assign Numbers

•Step 3: Select a Bar Code Printing Method

•Step 4: Select a “Primary” Scanning Environment

•Step 5: Select a Data Carrier

•Step 6: Pick a Bar Code Size

•Step 7: Format the Bar Code Text

•Step 8: Pick a Bar Code Colour

•Step 9: Pick the Bar Code Placement

•Step 10: Build a Bar Code Quality Plan

Step 1: Obtain a company prefix

Before a company can begin using bar codes, it must create the numbers that go inside the bar code. These numbers are called Identification Keys. The first step in building a Key is to obtain a Company Prefix from a GS1 representative.

Step 2: Assign numbers

After receiving a Company Prefix, a company is ready to begin assigning identification numbers to their trade items (products or services), to themselves (as a legal entity), locations, logistics units, individual company assets, returnable assets (returnable pallets, kegs, tubs), and service relationships.

The process is fairly simple. A GS1 representative can provide specific information about how many numbers can be assigned, based on the length of the Company Prefix.

Step 3: Select a bar code printing company

To begin, a company should decide what it is bar coding and if the bar code will encompass static or dynamic information. An example of static information would be simply a product identification number (GTIN) on a box of pre-packaged salad. An example of dynamic information would be printing serial numbers on product labels.

If the bar code has static information and a large volume of labels is needed, then a printing company can be engaged to print the labels. If the need is for a small volume of labels or for printing labels with dynamic information, an on-demand printer (such as a laser printer in the office or thermal transfer printer in a warehouse) would be required. Thus, knowing how the barcode is to be printed is important in developing a good bar code implementation plan. Again, a GS1 representative may be able to assist in making the right selection and can also help find a printer in the local area.

Step 4: Select a “primary” scanning environment

The specifications for bar code type, size, placement, and quality all depend on where the bar code is scanned. There are three basic scanner environment scenarios for trade items:

1.Product package scanned at the retail Point-of-Sale (POS)

2.Product package scanned in a general distribution

3.Product package scanned at POS but also scanned in distribution

By knowing where the bar code will be scanned, the right specifications for its production can be determined.

Step 5: Select a bar code

Selecting the right bar code is critical to the success of the bar code implementation plan, but here are some high-level tips:

•If the bar coded trade item is to be scanned at the retail Point-of-Sale (POS), a GS1 data carrier must be used. Loose produce intended for Point-of-Sale is labeled with appropriate GS1 bar code symbol.

•If a bar code is being printed with variable information such as batch/lot number, then a symbol called GS1-128 should be used.

Step 6: Pick a bar code size

After the correct bar code symbol is specified together with the information to encode in it, the design stage begins. The size of the symbol within the design depends on the symbol specified, where the symbol is to be used, and how the symbol is printed.

Step 7: Format the bar code text

The text beneath a bar code is important because if the bar code is damaged or of poor quality to begin with, then the text is used as a back-up.

Step 8: Pick a bar code colour

The optimum colour combination for a bar code symbol is black bars with a white background. If other colours are to be used, the following may help in choosing satisfactory ones:

•GS1 Bar Code Symbols require dark colours for bars (e.g., black, dark blue, dark brown, or dark green).

•The bars should always consist of a single line colour and should never be printed by multiple imaging tools (e.g. plate, screen, and cylinder).

•GS1 Bar Code Symbols require light backgrounds (e.g. white) which are to the left and right of the bar code

•In addition to light backgrounds, “reddish” colours may also be used. It is well-known that in a darkroom setting with red lighting, the text can virtually disappear. This is also true of similar colours such as orange, pink, peach, and light yellow. Given the fact that most bar code scanners use a red light source, these colours (orange, pink, peach, and light yellow) may be suitable for backgrounds, but should be avoided for bars.

•In many cases the symbol background is not printed. It is the colour of the substrate that is being printed. If the symbol background is printed beneath the bars, the background should be printed as solid line colours.

•If using multiple layers of ink to increase the background opacity, each layer should be printed as a solid.

•If using a fine screen to deliver more ink to the substrate, then it should be ensured that there are no voids in the print caused by the screen not adequately filling in.

Black bars and white spaces provide the optimal combination, but other colour combinations can be used. An experienced printer or a GS1 Member Organization can be consulted for additional guidance.

Step 9: Pick the bar code placement

Symbol location refers to symbol placement on the design. In addition, the packaging process should be considered. The packaging designer should be consulted to make sure that the symbol will not be obscured or damaged (e.g. over a carton edge, beneath a carton fold, beneath a package flap, or covered by another packaging layer).

9.2Other useful resources

10  APPENDIX 2: TRACEABILITY FORMS

10.1Growers forms

10.1.1Growers: sales receipt - receiving

10.1.2Growers: input control form

10.1.3Growers: sales receipt – dispatch

10.1.4Growers: farm book form

10.2Packinghouse/re-packer forms

10.2.1Packinghouse/re-packer: processing / packing form

10.2.2Packinghouse/re-packer: input control form

10.2.3Packinghouse/re-packer: sales receipt – dispatch

10.3Poultry processing/packing plant forms

10.3.1Poultry processing/packing plant - input control form

10.3.2Poultry processing/packing plant - processing_packing form

10.3.3Poultry processing/packing plant: poultry - shipment receipt

10.4Condiment manufacturer forms

10.4.1Condiment manufacturer - sales receipt receiving

10.4.2Condiment manufacturer - input control form

10.4.3Condiment manufacturer - sales receipt dispatch

10.4.4Condiment manufacturer - manufacturing process form

10.5Nutmeg processor forms

10.5.1Nutmeg processor: sales receipt - receiving

10.5.2Nutmeg processor: sales receipt – dispatch

10.5.3Nutmeg processor: control summary form

10.5.4Nutmeg processor: drying process form

10.5.5Nutmeg processor: packing process form

10.5.6Nutmeg processor: sales receipt – dispatch

10.6Cocoa processor forms

10.6.1Cocoa processor: sales receipt - receiving

10.6.2Cocoa processor: sales receipt – dispatch

10.6.3Cocoa processor: receiving form

10.6.4Cocoa processor: drying/packing process form

10.7Fish processor forms

10.7.1Fish processor: sales receipt - receiving

10.7.2Fish processor: sales receipt – dispatch

10.7.3Fish processor: input control form

10.7.4Fish processor: packing process form

10.8Poultry processor forms

10.8.1Poultry processor: sales receipt-receiving

10.8.2Poultry processor: input control form

10.8.3Poultry processor: sales receipt-dispatch

10.8.4Poultry processor: packing process form

10.9Supermarket – fresh produce forms

10.9.1Supermarket – fresh produce forms: input control form

10.9.2Supermarket – fresh produce forms: processing / packing form

[1] Draft Food Traceability and Recall Legislation Recommendations, developed under a project (TCP/SLC/3403) funded by the Food and Agriculture Organization (FAO)– “Strengthening capacity for a rapid response to food safety events through enhancement of the food traceability and recall legislation and systems in the Caribbean Sub region”, 2014 – 2016.

[2] Draft Food Traceability and Recall Legislation Recommendations, developed under a project (TCP/SLC/3403) funded by the Food and Agriculture Organization (FAO)– “Strengthening capacity for a rapid response to food safety events through enhancement of the food traceability and recall legislation and systems in the Caribbean Sub region”, 2014 – 2016..

[3] GTIN: Global Trade Item Number. Standardized number allocated by GS1 to identify a product

[4] Draft Food Traceability and Recall Legislation Recommendations, developed under a project funded by the Food and Agriculture Organization (FAO) under its Technical Cooperation Programme - TCP/SLC/3403 – “Strengthening capacity for a rapid response to food safety events through enhancement of the food traceability and recall legislation and systems in the Caribbean Sub region”, 2014 – 2016.

[5] Point of Sale (POS)- It is the place where a retail transaction is completed. It is the point at which a customer makes a payment to the merchant in exchange for goods.

[6] Authorities may consult the following two FAO/WHO guidance booklets that describe international best practices applied by different nations:

- FAO/WHO guide for developing and improving national food recall systems (http://www.fao.org/docrep/017/i3006e/i3006e.pdf); and

- FAO/WHO guide for application of risk analysis principles and procedures during food safety emergencies (http://www.fao.org/docrep/014/ba0092e/ba0092e00.pdf)

[7] http://eur-lex.europa.eu/legal-content/EN/TXT/?qid=1464803615568&uri=CELEX:32002R0178

[8] http://www.fda.gov/RegulatoryInformation/Legislation/ucm155733.htm

[9] http://www.fda.gov/Food/GuidanceRegulation/FSMA/ucm247548.htm

[10] http://www.gs1.org/traceability/traceability/1-3-0

[11] http://www.iso.org/iso/catalogue_detail?csnumber=36297

[12] http://www.iso.org/iso/home/store/catalogue_tc/catalogue_detail.htm?csnumber=62085

[13] http://www.iso.org/iso/home/store/catalogue_tc/catalogue_detail.htm?csnumber=35466

[14] http://www.brcglobalstandards.com/

[15] https://www.ifs-certification.com/

[16] http://www.sqfi.com/

[17] http://www.globalgap.org/

[18] Draft Food Traceability and Recall Legislation Recommendations, developed under a project (TCP/SLC/3403) funded by the Food and Agriculture Organization (FAO)– “Strengthening capacity for a rapid response to food safety events through enhancement of the food traceability and recall legislation and systems in the Caribbean Sub region”, 2014 – 2016.

[19] GS1 Global Traceability Standard – Business Process and System Requirements for Full Chain Traceability (GS1 GTS).

[20] ISO 22005:2007, Traceability in feed and food chain – General principles and basic requirements for system design and implementation.