Traceability requirements for hospitality and catering businesses

Today, I want to talk about what traceability is and why it is important.

I know it’s something that can cause a bit of confusion. I frequently get asked about it by small hospitality and catering businesses, as they sometimes struggle to understand their legal requirements in relation to this.

I also want to cover here the withdrawal and recall procedures, the responsibilities of Food Business Operators and what retail and catering businesses need to do in terms of traceability, including what records to keep and for how long.

What is traceability and why is it important?

Traceability involves keeping track of food products throughout the supply chain. This extremely helpful in the event that unsafe food needs to be withdrawn or recalled. For example; a food manufacturer could make a product and then determine that it’s unsafe. Depending on where it is in the food chain, this will determine whether a withdrawal or recall is needed.

What’s the difference between withdrawal and recall?

Withdrawal is where unsafe food is removed from the supply chain. It’s used when unsafe food has not yet reached the consumer.

A recall is once the unsafe food has reached the consumer, requiring the removal of the product from the market and advising consumers to take action, such as to return the food to the place they purchased it from or to throw it away.

For example, as a catering business, you could be contacted by your supplier informing you that you have been supplied with some food that’s potentially unsafe. In such cases, it’s important that you follow the supplier’s instructions to either return or dispose of the product.

There are many reasons a product could be deemed to be unsafe such as allergens present that shouldn’t be there or are not declared on the label or because bacteria have been found in some batches of a product.

In terms of traceability,  the more information a business keeps, the easier and quicker (and most likely cheaper) it is to identify the affected food and take the necessary actions to reduce the risks to consumers.

Responsibilities of Food Business Operators

As a Food Business Operator, you are responsible for the safety of the food you produce, distribute, store, or sell. In summary, you must:

• Not place unsafe food on the market
• Comply with food safety laws when producing, storing, distributing and selling food
• Be able to trace suppliers of your food/ingredients and business customers (other food businesses you supply)
• Remove unsafe food from the market in the event of a food safety incident

Essentially, if you put unsafe food on the market, it’s your responsibility to remove it once you identify it’s potentially unsafe.

In practice:

• You must have traceability information for your suppliers and business customers. Think one step back and one step forward.
• If you’re a retailer or caterer, you do not need to keep traceability information for food sold directly to the final consumer. But it’s important to understand how traceability works because you are receiving products from other businesses i.e. manufacturers and distributors that are required to meet these traceability requirements, so this can help you be more vigilant when choosing a reputable supplier.
• You must have systems and procedures in place to ensure that traceability information can be made available to enforcement authorities (i.e. your local authority) on demand.
• You must label or identify food placed on the market to facilitate its traceability. This applies to producers, distributors etc.
• Note that products of animal origin and sprouted seeds are subject to specific traceability requirements. You can find more information on traceability requirements on the FSA website.

Traceability requirements for Caterers

If you’re a caterer and your customers are the final consumer, you don’t need to keep a record of every person you’ve sold food to. However, if you supply food to other businesses, such as selling cakes to other cafes, you would need to keep traceability information around what you have supplied to these other businesses.

You do need to keep traceability information for your suppliers. This includes records of what food products and ingredients you’ve bought, who you bought them from, the quantity, and the date of purchase.

It’s a legal requirement to keep this information, so that you or an enforcement officer can trace the origins of any food products if needed.

How long should you keep these records for? Ideally, until you are sure that the food has been consumed without any problems.

How to keep traceability records

The easiest way to maintain traceability information is by keeping all your invoices and receipts. You might also want to record the information in a different way, for example keeping a record of the batch number and other details. But keep these records in a way that makes it easy for you or an enforcement officer to check them. In my experience, most retail and catering businesses have the invoices and receipts available for the officer to view during their food hygiene inspection.

What to do if you got notified of an issue

If your supplier notifies you of an issue with a product they’ve supplied, you have two main responsibilities:

1. Remove the unsafe food from sale or service.
2. Return the unsafe food to your supplier or dispose of it properly.

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References and more info:

Food Standards Agency Guidance on Food Traceability, Withdrawals and Recalls within the UK Food Industry

Food Standards Agency Guidance on Food Traceability, Withdrawals and Recalls within the UK Food Industry- Quick Reference Guide