Traceability records for freeze-dried ingredients are the goods-in and dispatch entries that tie each supplier lot to your own batch, kept so that one step back and one step forward can be shown to an authority on demand.

Article 18 of Regulation 178/2002 sets the minimum for traceability records

Article 18(1) of Regulation (EC) No 178/2002 puts traceability at “all stages of production, processing and distribution”. So your traceability records start at the goods-in gate. Paragraph 2 asks you to name “any person from whom they have been supplied”. That duty covers the food and every ingredient in it. Paragraph 3 adds the second half. You must also name the firms you supplied. Because both ways count, the file has two halves.

Paragraph 4 asks that food carries labelling or marks good enough to support the trace. Article 19 then turns the file into a plan. When you judge a lot unsafe, you pull it and tell the authority. Article 19(3) makes that notice immediate when the food may harm health. So the file matters most on the day a lot fails. A thin goods-in row can widen a recall to a whole month of output. A full row holds it to one pallet.

Four fields the Commission guidance expects in every entry

Commission guidance on the general food law names the minimum (European Commission). Four items belong to each deal. First, the “name, address of supplier, and identification of products supplied”. Second, the same pair for the customer. Third, the “date and, where necessary, time of transaction / delivery”. Fourth, the “volume, where appropriate, or quantity”. Batch codes go beyond that minimum, since the guidance calls them helpful and stops there.

Final consumers sit outside the trace, because the guidance says operators need not identify them. Deals between businesses carry the duty in full. A freeze-dried peach lot with no code cannot be traced once it feeds three orders. So log the supplier lot code, the country of harvest and the arrival date in one row. Then add your own pallet number. The row takes moments at goods-in, yet it narrows every later withdrawal.

What one row looks like for a peach dice delivery

Six fields cover most audits. They are supplier name and address, product name, supplier lot code, arrival date, net weight and your pallet number. Add the best before date when the carton shows one. Add the country of harvest when the spec calls for origin. Then the row answers both directions of Article 18 on its own. Keep the same field order in every system, because matching odd columns during a recall wastes hours.

How long to keep traceability records for a freeze-dried lot

Five years is the baseline in the same guidance. Two shortcuts cut that span for shorter-lived goods.

Product situation	Retention the guidance suggests
Highly perishable, shelf life under three months	6 months after the date of manufacture
Product carrying a “best before” date	Shelf life plus 6 months
Product with no durability date	5 years

Freeze-dried fruit shows a best before date, so the middle row applies. An 18-month best before gives 24 months of retention for that lot. Buyers often stretch the span by contract, since audits look further back than the guidance asks. Check the clause before you archive. A policy written for chilled goods will delete the wrong files.

Where the retention clock starts

Format stays open. Paper and digital files both count, once the entry stays legible and easy to find. Index by lot code first, because a recall starts from a code. Store the goods-in row, the delivery note and the batch map together. When the last pallet of a lot leaves, note the date on the same record. That date, plus the shelf life, gives you a clean end point for the file.

Lot marking under Directive 2011/91/EU and the durability exemption

Directive 2011/91/EU covers “indications or marks identifying the lot to which a foodstuff belongs”. Article 2 bars marketing of a foodstuff unless it carries that mark. Article 3 hands the call on the lot to the producer, the manufacturer or the packager. The first seller established within the Union may also make it. When goods are prepacked, Article 4 puts the mark on the pack or on a label fixed to it.

Article 5 opens the one exemption worth knowing. A date of minimum durability can stand in for the lot mark. The date must show at least the uncoded day and the month in that order. Bulk cartons of freeze-dried fruit usually carry both marks anyway. Keep both, because your traceability records key on the lot code. A coded date alone leaves you with nothing to search on.

Internal traceability links the supplier lot to your own batch

Commission guidance states the Regulation “does not expressly compel operators to establish a link between incoming and outgoing products”. So internal traceability stays optional in law. Auditors treat it as normal. Codex guideline CXG 60-2006 frames the tool as one that shows “from where the food came (one step back) and to where the food went (one step forward)” (FAO). Codex also warns that the tool “does not in itself improve food safety outcomes unless it is combined with appropriate measures”.

BRCGS says clause 3.9 of its Food Safety standard requires the system to meet the legal rules in the country of sale or intended use (BRCGS). So a certificate alone settles nothing. Map each supplier lot to the orders it fed. Then run a mass balance across that map. When the weight in and the weight out disagree, you have found a gap before an auditor does. Set a target time for the drill, and record the result each year.

Traceability records an official control asks to see

Article 15 of Regulation (EU) 2017/625 says operators “shall afford official controls” and cooperate fully. The same article asks for access to “all documents, records and facilities relevant to official controls” on request. Article 1(2)(a) sets the scope at food safety, integrity and wholesomeness at any stage. So one visit can reach goods-in files, dispatch notes and your batch map. Keep them in one place, since a scattered file reads as a weak system.

Volume gives the context. The Alert and Cooperation Network carried 10 490 notifications in 2025 (European Commission). That count runs 11 % above 2024, while alert notifications rose 14 %. Fruits and vegetables made up 18 % of the total, or 1 572 cases. Two thirds of those carried a potential health risk.

Border checks run before your gate

Imported consignments meet three layers of control at entry: documentary, identity and physical checks (European Commission). Ask your supplier which layer applied, and file the entry paperwork with the lot. The Commission frames traceability as the tool that “facilitates withdrawal of faulty food/feed from the market” (European Commission). So the row you write at goods-in continues a record that started at entry.

Key Data Elements apply to US shipments of listed foods

The FDA Food Traceability Rule rests on a Traceability Lot Code. FDA calls it “a descriptor, often alphanumeric, used to uniquely identify a traceability lot”. Seven Critical Tracking Events trigger records. They are harvesting, cooling, initial packing, first land-based receiving, shipping, receiving and transformation. Each event carries its own Key Data Elements. Files must reach FDA “within 24 hours after a request is made”.

Scope decides whether the rule reaches you. The FDA Food Traceability List covers fresh and fresh-cut produce. Dried and freeze-dried fruit stay off that list. The rule reaches a food holding a listed food only while that ingredient “remains in the same form (e.g., fresh) in which it appears on the list”. The compliance date now sits at 20 July 2028. Trade press reports the same date and the move to digital files, given the 24-hour window (FoodNavigator).

Data point	EU goods-in entry	US Key Data Element set
Counterparty	Name and address of supplier and customer	Name, address and point of contact
Product	Identification of the product supplied	Product description and lot code
Timing	Date, and time where needed	Date of each Critical Tracking Event
Quantity	Volume or quantity where relevant	Quantity and unit of measure

US buyers pass their own duties down the chain. Ask which of your items feed a listed food, then agree the data fields early. A supplier lot code plus a clear product description covers most of what they request. Keep the same code on the pack, on the delivery note and on the certificate of analysis. When the three disagree, the trace stalls at the first check.

Spec clauses that make the goods-in file work on day one

Article 8(8) of Regulation (EU) No 1169/2011 makes a supplier of food for other operators pass on “sufficient information”. That wording is broad, so pin it down in the spec. List the fields you want on every delivery note. Use the legal name of the food from Article 17(1). Add the supplier lot code, the best before date and the net weight. Add the operator name and address from Article 9(1)(h).

One more clause belongs in the same document. Ask for a timed traceability drill during onboarding, which also fits when you pilot a new freeze-dried ingredient supplier. Food Manufacture put the reason plainly after a year of high-profile recalls. Makers “cannot rely solely on supplier assurances” (Food Manufacture). Run the same drill across every category you buy, which the A to Z index of freeze-dried raw materials sets out by ingredient.

At SALESWAVE we confirm lot documentation for a given consignment once the documentation scope is agreed at the specification stage.

Frequently asked questions