Food traceability for small producers, in plain English
What traceability actually means, what the law expects of a small food business, what records to keep, and how to keep them without losing your evenings.
What traceability means
Traceability is being able to follow a food, and the ingredients in it, through every step: where you got it, what you did with it, and where it went. For a small producer it comes down to two questions you should be able to answer at any moment about anything you've sold:
- What went into it? Which ingredients, from which supplier, from which of their lots.
- Who got it? Which customers received product from that batch, and when.
If you can answer both quickly, you have traceability. Everything else is detail about how you keep the records.
What the law expects
In the EU, traceability is required of every food business by the General Food Law (Regulation 178/2002, Article 18). The UK kept the same rule after leaving the EU. The requirement is often summed up as one step back, one step forward:
- One step back. For everything you take in, know who supplied it and be able to identify what and when. In practice, keep the supplier's name, the product, the quantity, the date and the supplier's lot number.
- One step forward. For everything you send out to another business, know who you sent it to, what it was, how much, when, and your own batch code.
Within your own premises you connect the two, so that an incoming lot can be followed to the batches it went into and the customers those batches reached. The law doesn't specify how you keep the records, only that you can produce them for the authorities on request, and quickly.
Selling direct to the public at a market or farm shop doesn't require you to record each consumer, but you still need to know which batch was on sale on which day, so that a recall notice can be precise.
Separately, you must be able to state which of the 14 regulated allergens each product contains, and labelling law requires a lot mark on prepacked food. Keep both written down against each product.
The records you need
Three sets of records, linked together, cover a small producer:
| When | Record | Why |
|---|---|---|
| Something arrives | Supplier, product, quantity, date, supplier's lot number, best before | One step back. Also tells you what stock you have. |
| You make something | Your batch code, date, product, quantity, and which incoming lots went into it (with amounts) | The link in the middle. This is what paper systems most often lose. |
| Something leaves | Customer, date, product, quantity, your batch code. Waste and shop use too. | One step forward. Also makes your output reconcile. |
Keep them for the shelf life of the product plus a margin. For digital records there's no reason not to keep everything.
Lot numbers and batch codes
A lot (or batch) is a quantity of product made or packed under the same conditions. Your suppliers print a lot number on the bag, the box or the invoice. When they have a problem they recall by lot number, and the first thing they'll ask is whether you have that lot.
You give your own output a batch code for the same reason. A good code is short, unique and says something about when it was made, for example SDL-1017-01 for the first sourdough batch on 17 October. SmartTrace generates codes like this automatically and prints them on a QR label so they can be scanned rather than typed.
Forward and backward tracing
Forward tracing starts at an ingredient and works outwards. Your flour mill rings to say lot KM-SW-24402 is being recalled. You need every batch that used it and every customer who received those batches. That's a forward trace.
Backward tracing starts at a product or a customer and works inwards. A café says Tuesday's scones were off. You need to know which batch they got, what went into it, and which other customers got the same batch. That's a backward trace.
You need both, and you need them in minutes. This is where linked records pay for themselves.
Paper, spreadsheet or software
Paper satisfies the law if it's kept well. Its weaknesses are speed and gaps. Finding every batch that used one delivery means reading back through weeks of sheets, and a single missed entry breaks the chain at the worst moment.
A spreadsheet is easier to search but hard to keep linked as it grows, and harder still to update from a phone with floury hands. Many producers start here and move on when volume picks up.
Purpose built software links the records for you as you go, so when you need a trace the system produces it in seconds. You type in a lot number; it does the rest. The historical objection was price, because traceability systems were built for factories. That's changed: SmartTrace is €25 a month, runs on the phone you already have, and is aimed squarely at producers with a handful of staff or none.
What an inspection looks like
An environmental health officer or inspector will generally pick something and follow it. They might lift a product off your shelf and ask you to show where its ingredients came from, or pick a delivery docket and ask what you made with it and who got it. They're looking for a complete chain, dates that make sense, and records you can find without an hour's searching.
Being able to hand over a printed or exported trace in a couple of minutes changes the tone of the visit. It also tends to shorten it.
Where to start
- List your ingredients and who supplies each one.
- Write down your recipes with quantities for a standard batch.
- From tomorrow, record every delivery with its lot number, every batch with the deliveries it used, and every dispatch with the customer and batch.
- Once a month, pick a lot at random and trace it both ways. If it takes more than a few minutes, fix the system.
If you'd like software to do the linking, here's how SmartTrace does it, and the first week is free.
Traceability questions and answers
What does traceability mean in food?
Traceability is being able to follow a food, or an ingredient in it, through every step from where you got it to where it went. In practice it means you can answer two questions quickly: what went into this product, and who did we sell it to?
What is 'one step back, one step forward'?
It's the minimum most food law asks of a food business. One step back: for everything you take in, know who supplied it and be able to identify the batch. One step forward: for everything you send out, know which business you sent it to and which batch it was. Within your own four walls you link the two, so a problem at either end can be contained.
Do small food producers legally need traceability?
In the EU and UK, yes. Any business that produces, processes or distributes food must be able to identify its suppliers and its business customers and produce that information to the authorities on request. The rule applies regardless of size. Direct sales to consumers at a market or farm gate don't require you to record the individual consumer, but you still need to know which batch you sold that day.
What is a batch or lot number?
A code that identifies a quantity of product made or packed under the same conditions. Your supplier prints theirs on the bag, box or invoice. You give your own batches a code too, so that when a problem arises you can say exactly which units are affected rather than throwing everything out.
What records do I need to keep?
For each thing you take in: the supplier, what it was, the quantity, the date and the supplier's lot number. For each thing you make: your batch code, the date, and which incoming lots went into it. For each thing you send out: the customer, the date, what it was, how much, and your batch code. Keep them long enough to cover the shelf life of the product plus a sensible margin.
How quickly do I need to produce traceability records?
Fast. Inspectors generally expect the information within hours, not days, and in a live recall the clock matters. A system that produces the full trace for you in a minute, ready to print, is the difference between a contained problem and a general one.
Can I do traceability on paper?
You can, and many small producers do. A delivery book, batch sheets and a dispatch book, kept carefully, satisfy the law. The weaknesses are speed, legibility and gaps: finding every batch that used one bag of flour means reading through weeks of sheets, and one missed entry breaks the chain.
Can I do it in a spreadsheet?
Yes, and it's better than paper for searching. The difficulty is keeping the links between deliveries, batches and dispatches straight as the sheet grows, and getting anyone to update it from a phone in a busy kitchen. Most producers who start with a spreadsheet move to purpose built software once volume picks up.
What is a product recall and how does traceability help?
A recall is removing a product from sale, and from customers, because it may be unsafe or mislabelled. Traceability tells you which batches are affected and which customers received them, so you can recall precisely rather than everything. See our short guide to running a recall for the steps.
What is HACCP and how is it different from traceability?
HACCP is your food safety management system: identifying hazards and the points where you control them, like cooking and chilling temperatures. Traceability is the record of where things came from and went. They work together: HACCP keeps food safe, traceability lets you act if something slips through. Many producers keep temperature records in a separate system; SmartTrace's sister product SmartChef does exactly that.
Do I need to record allergens?
You must be able to tell customers which of the 14 regulated allergens are in each product, and get it right. Keep a written allergen list for every product and review it whenever a recipe or an ingredient changes.
What does an inspector actually ask for?
Typically: show me where this ingredient came from, show me what you made with it, show me who got it, and show me the dates. They'll pick something off your shelf or from your records and follow it. They're looking for a complete chain and for records you can actually find.
How long should I keep traceability records?
At least as long as the product could still be in use, which means shelf life plus a margin. Many authorities suggest a minimum of a year beyond shelf life for ambient foods, or six months for very short life products. Digital records cost nothing to keep, so most producers simply keep everything.
What is forward and backward tracing?
Backward tracing starts from a finished product or a customer and works back to the ingredients and suppliers. Forward tracing starts from an ingredient or a supplier's lot and works out to the batches, dispatches and customers it reached. A recall by your supplier needs forward tracing; a customer complaint needs backward tracing. You need both.
Is traceability software expensive?
It used to be, because it was built for large manufacturers. SmartTrace is €25 a month with everything included and no contract, which puts it within reach of a one-person bakery.
Does traceability help with anything besides compliance?
Yes. Knowing how much of each ingredient went into each batch gives you real costings and real yields. Seeing stock levels stops you running out. Dispatch records make invoicing and reconciliation easier. Producers often find the by-products are worth as much as the compliance.
Get the full trace in seconds, not an evening.
SmartTrace links your deliveries, batches and dispatches for you. We set it up with you for free, then €25 a month, no contract.