Background Paper

Principles of Traceability/ Product Tracing

The Issue: In 2000, “traceability” became a global discussion topic and nations began to impose unnecessarily prescriptive regulatory standards for tracing products (traceability) to respond to highly publicized food safety scares. In 2001, The Codex Alimentarius Commission noted that the matter of “traceability” had been raised in several Codex Committees and Task Forces, and agreed that it was necessary for Codex to respond in a uniform matter. After several years of discussion including several physical working groups, following the elaboration of a definition for traceability/product tracing, the Commission adopted Principles for Traceability/Product Tracing as a Tool within a Food Inspection and Certification System in 2006. The Codex Committee on Food Import and Export Inspection and Certification Systems (CCFICS) recognized that traceability, as a tool that can contribute to the protection of consumers and to the facilitation of trade. The Principles adopted call for justification and defined objectives, a full food chain approach, and tracing one step forward and one step back.

Status: When the Principles were adopted by the Commission in 2006, several delegations expressed the view that guidance for traceability was also needed. In 2008, CCFICS created an electronic working group to solicit views from delegations on the need for further guidance on traceability/product tracing. In addition, the Regional Coordinating Committees were asked to consider the need for further work; the Codex Committee from Europe was interested in further work but no specific proposals have come forward and the issue has not been on the Codex agenda since 2011.

Background: In Codex, France first proposed work on traceability in the ad hoc Task Force on Food Biotechnology, seeking to gain international endorsement of EC proposals for traceability and labeling of products derived from biotechnology. The ad hoc Codex Intergovernmental Task Force on Animal Feeding also included a controversial reference to traceability within the Code of Practice. The Codex Committee on Food Import and Export Inspection and Certification Systems (CCFICS), noted that “the concept of traceability cuts across a wide range of food issues,” is not exclusively related to biotechnology, and is relevant to food trade. Within a year, traceability was being discussed in at least seven different Codex Committees.

The CAC adopted a definition for traceability that had been put forward by CCGP in 2002 as follows: The ability to follow the movement of food through specific stage(s) of production, processing and distribution. The Principles ultimately adopted by CAC in 2006 cover the context, rationale, design and application as a tool for use by competent authorities within the context of a food inspection and certification system.

Industry Engagement: The initial introduction of traceability within the context of foods for biotechnology generated significant political controversy. The ICGMA and others had actively opposed the European regulations requiring the labeling and tracing of products derived from biotechnology and was extremely opposed to the introduction of traceability within the context of Codex work. The food industry did not support traceability for the purposes of consumer information but recognized the broader need for tracking and tracing within the context of risk management. Industry groups, including ICGMA supported tracing principles that: (1) had a clearly justified objective related to food safety of fair trade practices; (2) was limited to the steps in the food chain necessary to achieve that objective; (3) was the least trade restrictive measure to achieve that objective; (4) take into consideration the costs and benefits and the technical limitations to assure accuracy and credibility; and (5) allowed necessary flexibility to meet operational and market needs.