Legally seen article 18 is primarily important here. This is (abstract of the article):

1. The traceability of food, feed, food-producing animals, and any other substance intended to be, or expected to be, incorporated into a food or feed shall be established at all stages of production, processing and distribution.
2. Food and feed business operators shall be able to identify any person from whom they have been supplied with a food, a feed, a food-producing animal, or any substance intended to be, or expected to be, incorporated into a food or feed. To this end, such operators shall have in place systems and procedures which allow for this information to be made available to the competent authorities on demand.
3. Food and feed business operators shall have in place systems and procedures to identify the other businesses to which their products have been supplied. This information shall be made available to the competent authorities on demand.
4. Food or feed which is placed on the market or is likely to be placed on the market in the community shall be adequately labelled or identified to facilitate its traceability, through relevant documentation or information in accordance with the relevant requirements of more specific provisions.(…)

Till now, the transformation of the EC regulation into a national legislation hasn't been completed yet. Therefore it can only be speculated, how and under which conditions the German Federal Government will ensure the traceability and which requirements on the companies concerned will be made. An EC execution ordinance to the Regulation (EC) 178/2002 with an e.g. exact definition of e.g. batch sizes is still missing. A national execution ordinance probably won't be issued.

All companies which are affected by these difficulties should start out from a maximum of requirements and provide traceability to a large extent (worst-case scenario). If the specifications should turn out to be of a lower extent, then the fulfillment of the requirements is no problem, but in the opposite case?!
Do your records already meet these requirements of a traceability to a large extent?
Is your warehouse administration software or your merchandise management system (ERP) already able to ensure the traceability of batch sizes to the customer and back to the supplier?

We are ready to assist you with the reply to these questions.

Please contact us .

Download the Regulation (EC) 178/2002 of the European Parliament and of the Council of 28 January 2002 (PDF, 232 KB)