Ian Thomas Associates

Food of animal origin – traceability requirements with effect from 1st July 2012

The ability of a food business to properly trace foodstuffs is crucial in the event of a food crisis requiring the removal of unsafe food from the market. From 1st July 2012, there are additional traceability obligations in respect of food of animal origin when Regulation (EU)  931/2011 takes effect.

Faced with a food crisis, food business operators must respond quickly and effectively to identify and trace unsafe food. Failure to do so will result in delay leading to increased cost and increased damage to reputation.  As noted in the new Regulation, previous food crises have shown that documentary records “were not always sufficient to allow full traceability of suspect foods”.

The new Regulation requires food business operators to make certain information available to other food business operators to whom food of animal origin is supplied. The information must also be made available, “without undue delay”, to the competent authority.

The Regulation affords the food business operator a degree of flexibility in the way the required information is made available as long as the required information is “clearly and unequivocally available to and retrievable by the business operator to whom the food is supplied”.

The required information, which is to be updated on a daily basis, is:

An accurate description of the food; the volume or quantity of the food; the name and address of the food business operator from which the food has been dispatched (and the name of the consignor (owner) if different); the name and address of the food business operator to whom the food is dispatched (and the mane and address of the consignee (owner) if different); a reference identifying the lot, batch or consignment; and the date of dispatch.

The (EU) Regulation states that the information be kept available until it can reasonably be assumed that the food has been consumed. Food business should however be aware that Irish domestic law requires documents to be retained for three years and EU Guidance suggests that for taxation purposes most records should be kept for five years.

Food business operators dealing with food of animal origin must ensure that they have procedures and   systems in place to meet the requirements of the new law.

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