Food Traceability Software: What Article 18 Requires

Traceability is the only food safety record that runs when something has already gone wrong. Everything else in your system proves you did things correctly. This one answers a different question, under time pressure, usually on the phone to a supplier or a customer.

That question is: where did it go, and what else is affected?

What the law actually requires

Regulation (EC) 178/2002 applies in Ireland and is retained in UK law. Article 18 requires every food business operator to be able to identify:

• Any person who supplied them with a food, a feed, a food producing animal or any substance intended to be incorporated into a food
• Any business to which their own products have been supplied

This is usually shortened to one step back, one step forward. Article 19 then covers what happens next: if you have reason to believe a food you placed on the market is unsafe, you must withdraw it and inform the competent authority.

Two points people miss. The law does not require any particular system, so paper is legal. And it requires the information to be available on demand, which is where paper systems fail in practice rather than in principle.

What traceability encompasses

The integrated processes that let you track inputs and outputs across the chain:

• Recording supplier detail at goods in, including their batch or lot code
• Assigning your own batch codes at the point of production
• Linking ingredient batches consumed to the runs that consumed them
• Documenting in house processing activities against those runs
• Logging what was dispatched, in what quantity, to which customer

Miss any one of those and the chain has a break in it. The forward half, dispatch to customer, is the half most often missing, and it is the half you need when a withdrawal is called.

Two cases that changed food law in Ireland and the UK

Horse meat, 2013

In January 2013 the Food Safety Authority of Ireland published results of a DNA testing programme that found equine DNA in beef burger products on sale in Irish and UK supermarkets. What followed was a Europe wide scandal that pulled in processors, brokers and cold stores across several countries.

It was not a food safety incident in the strict sense. Nobody got ill. It was a traceability and authenticity failure, and it happened because supply chains had more links in them than anyone could account for. The response reshaped supplier verification and product authenticity requirements across the industry, and it is why authenticity now sits inside schemes like BRCGS rather than being treated as a commercial matter.

Pret A Manger and Natasha’s Law

In 2016 Natasha Ednan Laperouse, aged fifteen, died after eating a baguette containing sesame that was not declared on the label. The product was prepacked for direct sale, a category that at the time did not require a full ingredient list.

The outcome was the Food Information (Amendment) Regulations, known as Natasha’s Law, which came into force in the UK in October 2021 and requires foods prepacked for direct sale to carry a full ingredient list with allergens emphasised. Ireland has equivalent requirements for prepacked for direct sale foods, and you should confirm your own position with the FSAI.

The practical consequence for traceability is direct. You cannot label what you cannot trace. If you do not know which ingredient batch went into which product run, you cannot say with confidence what is on the label, and you cannot answer a customer asking which of your products contain sesame. This bites hardest in bakery and deli operations, where allergens are the dominant hazard.

Why paper traceability fails

Not through carelessness. Through structure.

• Data sits in separate places. Delivery dockets in one folder, production diaries in another, dispatch notes in a third, often in different rooms and different handwriting.
• The chain has gaps. A link that was obvious to the person making it on the day is not obvious to anyone reading the record eight months later.
• It takes time you do not have. Reconstructing a chain by hand takes an afternoon. A withdrawal gives you hours, and every hour is product still on shelves.
• Audits become painful. Scheme auditors run a timed traceability exercise. Paper systems are where sites lose that mark.
• Recalls get wider than they need to be. This is the one that costs real money. If you cannot show which runs used the affected lot, you withdraw everything from that window rather than the batches that actually contain it.

What traceability software actually does

The useful distinction is not features. It is when the links get made.

At goods in

Supplier, product, quantity, their batch or lot code, use by date and delivery temperature captured as the pallet comes off the van, with the docket photographed against the record. Entered at the door rather than transcribed later, while it is still accurate.

At production

Each run gets its own code, with the ingredient batches it consumed attached to it. This is the single most important link in the chain, and it is the one paper systems most often reconstruct from memory.

In the recipe

Products, recipes and the ingredients inside them held centrally, with allergen information carried against each ingredient. A query about one ingredient then resolves to every product containing it, rather than to whatever somebody remembers.

At dispatch

Batches linked to orders and customers, with dates and quantities. The forward half of the chain, and the half that gives you a call list when a withdrawal is called.

On demand

Enter a supplier lot and get the production runs that used it, the finished products those runs made, and the customers who received them. Enter a finished batch and work backwards to the delivery. Export the chain with quantities that reconcile for mass balance.

See how this works in Food Guard traceability, and how Greenaway Foods turned audit preparation into a search. In butchery the same chain runs from carcass to individual cut, and in retail it runs from goods in to date code sweeps across an estate.

What to look for when choosing a system

Ignore feature lists and test three things:

1. Run a trace on your own data. Not a demo dataset. Your suppliers, your products, your batch codes. Time it.
2. Check the forward half. Plenty of systems record goods in well and dispatch badly. Ask to see a trace that ends at a named customer with a quantity.
3. Ask what happens at audit. Can it export the chain for one batch, with quantities in and out, in a format an auditor will accept without you reformatting it?

Practical things that matter more than they sound: whether staff can capture goods in on a phone at the door, whether it works with no signal in a cold store, and whether adding a user costs anything. A system only two people are licensed for will not be used at goods in on a Sunday.

Mock recalls and traceability tests

Do not wait for an auditor to be the first person who tests this.

A mock recall picks a batch at random and runs the exercise as if it were real: identify the affected product, quantify it, identify the customers who received it, and produce the records. Scheme audits run a timed version of exactly this, and BRCGS includes it as part of the audit.

Run one yourself, twice a year, and time it. The result tells you more about your traceability than any policy document, and the gaps it finds are cheap to fix in advance and expensive to find during a withdrawal. Traceability sits alongside your HACCP plan rather than separately from it, and both are assessed together at a BRCGS audit.

Frequently asked questions