Traceability & Recall Readiness for Traded Products
Aligned with BRCGS Food Safety Issue 9 – Section 9.1.3 & 9.1.4
Requirement Overview
BRCGS Food Safety Issue 9 Section 9.1.3 and 9.1.4 requires:
Clause 9.1.3 – The company shall ensure that suppliers of traded products are approved and that the products are traceable.
Clause 9.1.4 – Where the site is responsible for the recall of traded products, it shall have procedures in place to effectively manage such events, including a documented recall plan.
Facilities that handle traded products—products manufactured off-site but stored, sold, or distributed by the certified facility—must ensure full traceability and recall readiness just as they would for in-house products.
Aligned with BRCGS for Storage & Distribution Issue 4 – Clause 4.3.1 & 4.3.3
Requirement Overview
BRCGS for Storage & Distribution requires that products moved via cross-docking are traceable and controlled at all times, even when they are not held in storage for extended periods.
Clause 4.3.1: “The company shall ensure that traceability is maintained at all stages, including during cross-docking operations.”
Clause 4.3.3: “Procedures shall be in place to ensure that all products handled, including those not stored on-site, remain under control and are not subject to contamination or substitution.”
Cross-docking operations must not compromise product traceability, safety, or integrity. Even with minimal handling and temporary presence, each product must be accurately identified, documented, and protected.
Key Compliance Objectives
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✓ Ensure traded products are traceable one step forward and one step back
✓ Maintain up-to-date supplier approval documentation
✓ Be prepared to execute a full recall for traded products
✓ Document all tests, communications, and corrective actions
Step-by-Step Compliance Implementation
1. Establish Supplier Approval and Documentation
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Approval Requirements:
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• Supplier must meet the site’s food safety expectations
• Documentation includes certificates (e.g., GFSI), specifications, and supply chain records
• Maintain risk assessment for each traded product source
Evidence to Maintain:
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• Approved supplier list
• Supplier certificates and specifications
• Product traceability agreements or contracts
- • Supplier must meet the site’s food safety expectations • Documentation includes certificates (e.g., GFSI), specifications, and supply chain records • Maintain risk assessment for each traded product source
- • Approved supplier list • Supplier certificates and specifications • Product traceability agreements or contracts
2. Maintain Traded Product Traceability
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Traceability Must Cover:
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• Supplier → Storage → Distribution → Customer
• Batch/lot coding for full product journey
• Distinct identification of traded vs. in-house products
Evidence to Maintain:
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• Incoming and outgoing product logs
• Batch coding and shipping documentation
• Cross-reference to supplier and customer data
- • Supplier → Storage → Distribution → Customer • Batch/lot coding for full product journey • Distinct identification of traded vs. in-house products
- • Incoming and outgoing product logs • Batch coding and shipping documentation • Cross-reference to supplier and customer data
3. Document Recall Procedures for Traded Products
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Recall Plan Must Include:
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• Specific procedures for handling recalls of traded goods
• Roles and responsibilities (including communication with supplier/manufacturer)
• Access to current distribution records and mock recall testing
Evidence to Maintain:
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• Traded product recall procedure
• Recall team structure and contact list
• Distribution matrix and recall flow diagram
- • Specific procedures for handling recalls of traded goods • Roles and responsibilities (including communication with supplier/manufacturer) • Access to current distribution records and mock recall testing
- • Traded product recall procedure • Recall team structure and contact list • Distribution matrix and recall flow diagram
4. Conduct Annual Mock Recall Including Traded Products
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Mock Recall Must Test:
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• Speed and accuracy of tracing a traded product
• External communication with suppliers and customers
• Team’s familiarity with recall roles and process
Evidence to Maintain:
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• Mock recall scenario report involving a traded item
• Trace logs showing one-up/one-down verification
• Evaluation forms and corrective actions
- • Speed and accuracy of tracing a traded product • External communication with suppliers and customers • Team’s familiarity with recall roles and process
- • Mock recall scenario report involving a traded item • Trace logs showing one-up/one-down verification • Evaluation forms and corrective actions
Common Audit Findings & Recommended Fixes
| Audit Finding | Recommended Action |
|---|---|
| No recall procedure for traded products | Add traded products to recall SOP; define roles and communication |
| Traceability only tracked internally | Include supplier and distribution-level tracking in trace system |
| Suppliers not properly vetted | Perform documented supplier approval and ongoing verification |
| Mock recalls exclude traded products | Integrate traded SKUs into annual recall testing |