Traceability Systems
Aligned with BRCGS Food Safety Issue 9 – Clause 3.9
Requirement Overview
BRCGS Food Safety Issue 9 requires that certified sites implement a traceability system capable of identifying product lots and their link to raw materials, packaging, processing, and distribution.
Clause 3.9.1:
“The site shall maintain a traceability system which enables the identification of product lots and their relation to batches of raw materials, primary packaging materials, and processing records.”
The traceability system must allow the site to trace one step forward and one step back, enabling rapid identification and withdrawal of affected products in the event of a safety or quality issue.
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 full traceability from raw materials to finished product
✓ Support effective and timely recalls or withdrawals
✓ Meet legal, regulatory, and customer traceability expectations
✓ Maintain traceability documentation and test traceability annually
Step-by-Step Compliance Implementation
1. Map the Traceability Flow
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Steps to Include:
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• Identify traceability points for raw materials, packaging, WIP, and finished goods
• Assign unique batch/lot codes
• Link materials to supplier and processing data
Evidence to Maintain:
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• Process flow diagrams with traceability checkpoints
• Traceability matrix (raw → process → product)
• Sample lot codes and trace logs
- • Identify traceability points for raw materials, packaging, WIP, and finished goods • Assign unique batch/lot codes • Link materials to supplier and processing data
- • Process flow diagrams with traceability checkpoints • Traceability matrix (raw → process → product) • Sample lot codes and trace logs
2. Implement Batch Coding and Labeling
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Requirements:
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• Clearly marked, legible, and consistent codes
• Link to production and distribution records
• Integration with inventory and dispatch systems
Evidence to Maintain:
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• Batch coding SOPs
• Label samples and coding formats
• Labeling checks and verification logs
- • Clearly marked, legible, and consistent codes • Link to production and distribution records • Integration with inventory and dispatch systems
- • Batch coding SOPs • Label samples and coding formats • Labeling checks and verification logs
3. Maintain Supplier and Ingredient Trace Records
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Tracking Should Include:
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• Ingredient origin, batch numbers, and delivery details
• Packaging materials traceability
• Receiving inspection records
Evidence to Maintain:
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• Supplier batch records and delivery logs
• Receiving QC checklists
• Approved supplier list with trace links
- • Ingredient origin, batch numbers, and delivery details • Packaging materials traceability • Receiving inspection records
- • Supplier batch records and delivery logs • Receiving QC checklists • Approved supplier list with trace links
4. Track Finished Product Distribution
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Key Points:
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• Link finished goods to dispatch records
• Maintain customer-level distribution records
• Integrate lot tracking into ERP or manual logs
Evidence to Maintain:
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• Shipping logs and invoices
• Dispatch checklists with batch links
• Customer trace logs
- • Link finished goods to dispatch records • Maintain customer-level distribution records • Integrate lot tracking into ERP or manual logs
- • Shipping logs and invoices • Dispatch checklists with batch links • Customer trace logs
5. Test the Traceability System Annually
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Test Objectives:
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• Trace selected product back to all inputs and forward to destination
• Complete the trace within 4 hours
• Identify any gaps in documentation or system breakdowns
Evidence to Maintain:
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• Trace test reports
• Completed traceability drills
• Corrective actions and system improvements
- • Trace selected product back to all inputs and forward to destination • Complete the trace within 4 hours • Identify any gaps in documentation or system breakdowns
- • Trace test reports • Completed traceability drills • Corrective actions and system improvements
Common Audit Findings & Recommended Fixes
| Audit Finding | Recommended Action |
|---|---|
| Incomplete or delayed trace results | Conduct mock traceability drills and improve record linkage |
| No documented traceability system | Implement and maintain a written traceability SOP |
| Unreadable or inconsistent batch codes | Standardize and audit batch labeling protocols |
| Missing supplier trace documentation | Require delivery, batch, and COA records for all incoming goods |
