The need for coordinated traceability in the food chain became apparent in the 1990s following a number of food crises in Europe, most notably the BSE crisis. Traceability was subsequently adopted as a core principle of EU food law in Regulation (EC) No 178/2002.
The Regulation establishes that all food business operators must comply with the “one step forward, one step back” approach, i.e. they must be able to identify the businesses to which their products have been supplied and to trace food chain inputs back to the immediate supplier.
One notable exception is that customer traceability is not required for operators who sell solely to the final consumer.
The Regulation provides that food which is likely to be placed on the market must be labelled to facilitate its traceability and the traceability of food must be established at all stages of production, processing and distribution.
In general food law does not prescribe the traceability information which should be maintained by food business operators. However, there is a variety of sector-specific legislation which outlines minimum requirements for different food industries. The Food Safety Authority of Ireland (FSAI) has also issued detailed guidance outlining the traceability information which it recommends operators should maintain. Food business operators must have systems in place which enable them to make traceability information available to the FSAI on demand.
The Irish food industry has made a sustained effort to ensure that there are comprehensive traceability systems in place in the food chain. This is an essential component of ensuring consumer confidence in Irish food. Delays in identifying the source of food products can lead to extended adverse media coverage for a food business operator and the wider food industry, as the recent horsemeat controversy demonstrated. It can therefore be expected that traceability is likely to remain a high priority for the Irish food industry for the foreseeable future.