In brief, we bring in our products in bulk and repack them (exposed) into our various sizes. There is no further 'processing' just repacking.
We put the best by date of manufacture (co-manufacturer's date) on the package as well as a Julian date lot code so we know what day it ran in house. We do NOT track in our system to the customer, however, the LOT. We only track the best by date printed.
So far the reasoning behind this is that if we had a recall, it would be because of something within the product and would need to flow back to the manufacturer. The risk of any sort of legitimate recall coming from in-house production (based on the LOT) is slim to none.
So what I can't figure out is for our small business operation, what is necessary in order to be compliant? Do we need to be able to trace our day of repacking downstream?
In the event that there's a recall, we would recall by best by date anyways in which case we would be acting as over-precautious.