Traceability: A Step too Far?

Traceability is defined by Art 3(15) as ‘the ability to trace and to follow a food, feed, food producing animal or substance intended to be or expected to be incorporated into a food or feed, through all stages of production, processing and distribution’. Art. 18 specifies that food and feed business operators must be able to identify any person from whom they have been supplied. To achieve this food and feed business operators must have in place systems and procedures, which allow for this information to be made available to the Competent Authorities on demand. The requirement covers all stages of production, processing and distribution, i.e. from the point of import or primary production up to the retail outlet.

This issue of Trade Hot Topics examines the issue of traceability. It looks at the impact on developing countries of what is seen as an ‘extended’ requirement for traceability beyond what the EU legislation actually stipulates. The principal drivers of this extended requirement are also examined and the question raised as to whether the existing powers of the WTO (and other relevant bodies) which is charged with the orderly regulation of international trade should be enhanced to deal with the impact on international trade of the current unregulated impact of extended traceability through private sector importers.