One-up one-down traceability should not present problems, as suppliers know who they buy from and who they sell to.
However, failure to control precisely which in-bound batch materials end up in which outbound shipments could cause problems for suppliers, warned Lawrence Hutter, Deloitte head of European consumer business.
“Let’s say you are making beefburgers and use the offcuts from one batch in your next batch and offcuts from that
batch in the next one and so on. If a problem is discovered with a shipment of raw materials, there may be no way of knowing which batches of finished product they are in. A blanket recall would have to go out.”
It was also difficult to see how suppliers would be able to supply all the relevant information to satisfy the law on demand - perhaps in hours - if they were relying on paper record-keeping, he said. “Take the above scenario for chicken and bear in mind that you may have to trace records that are several years old.”