Traceability and consumer protection in restaurants

In 2024, with the delegation of health controls to external bodies, the number of inspections at food sector establishments with direct delivery to the consumer is expected to increase by 80%. Traceability, an essential component of the HACCP method, is part of the regulatory requirements for restoration. It is the backbone of food quality and safety approaches.

WHAT ARE THE REGULATORY OBLIGATIONS?

EC Regulation No. 178/2002 defines traceability as "the ability to trace, through all stages of production, processing and distribution, the path of a food or feed, an animal that produces food or a substance that is intended or likely to be incorporated into a food or feed.”

Food business operators must be able to identify their suppliers and the people to whom they have supplied and delivered food. They are free to choose the traceability system that suits them, whether handwritten or digital.

However, Article 18 of the Regulation imposes an obligation of results (not means), which may be checked during an inspection by the official services. As the legal responsibility of the operators is recognized by the regulations, administrative penalties such as fines or criminal penalties with prison sentences may be administered by the official services.

WHAT IS A TRACEABILITY TEST?

During an inspection by official controls, the inspector may perform a traceability test:
– On a raw material: you must know the origin of your product, identify your supplier and be able to prove the quality of your product (delivery notes to keep)
– On a finished product: you must track your product, from the receipt of raw materials to the distribution of the finished product to the final consumer (list of ingredients used for each recipe with the batch number and expiry date). It is recommended to carry out these traceability tests internally at least once a year to ensure the effectiveness of its traceability system.

ARE YOU READY FOR AN INSPECTION?

During a control by the official services, the inspector will check the effectiveness of your traceability system.

The following documents will be requested:
– Your suppliers’ delivery notes
– Labels of all food used in the establishment
– Labels and recipe sheets for on-site cooked preparations

In the general case, the information must be kept for at least 5 years from the date of manufacture or the date of delivery (shipping/ receipt). Except for foodstuffs with a DLC of less than three months, the shelf life of traceability documents is 6 months from the date of manufacture or production.

WHICH TRACEABILITY SYSTEM TO CHOOSE?

Each institution is free to choose its traceability system, whether handwritten or digital. Thus, the labels of the raw materials can be cut and archived during the recommended archiving period of 6 months or 5 years depending on the case. This method, although easy to access, can be tedious especially in case of control. Indeed, it can be difficult to find the label of the controlled product among all the labels kept.

The other solution is to photograph the labels and save them in a digital application, such as traqfood. During a control, this allows you to find in a few seconds the label of the controlled product and thus be serene in front of the inspector. You can also save your delivery notes in the application, receive alerts as consumption deadlines approach, manage your secondary DLC and ensure traceability on a registered recipe.

It is essential that your security system is effective in order to guarantee the safety of your consumers and to comply with the regulations.

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