From the Interpretation Guide:
Interpretation Supply chain traceability
It is important for the integrity of products that appropriate traceability systems operate throughout the
supply chain. Therefore, sites must ensure that their raw material suppliers (excluding packaging
suppliers) have suitable traceability systems in operation. This assurance can be obtained from
certification, auditing or by directly testing traceability. Examples include:
• Where the raw material supplier is certificated to a GFSI-benchmarked standard – assessment of
traceability systems forms part of these audits and therefore no additional action is required to
comply with the requirements of this clause; however, a communication mechanism should be in
place, such that if the raw material supplier was no longer certificated, the site is made aware of this
• If the raw material supplier is audited by the site and the audit includes an assessment of the
traceability systems, this complies with the requirement of clause 3.9.3 as traceability has been
assessed. The audit should be repeated at least every 3 years.
• If supplier approval is based solely on a questionnaire with no additional testing of the traceability
system, additional traceability verification is required unless the raw material is a primary agricultural
product purchased directly from a farm or fishery, where additional testing of the traceability
systems is not mandatory. This verification could include, for example:
– A test of the raw material supplier’s traceability. For example, as part of the site’s traceability test
(refer to clause 3.9.2) a relevant ingredient is highlighted. The ingredient and batch details for the
material are forwarded to the supplier to enable them to complete the traceability test for the
specific batch of raw materials and forward the relevant records back to the site.
– A worked example from the raw material supplier, which clearly shows how the traceability works.
– A detailed description of the traceability system, provided by the raw material supplier.
Information received during the traceability verification should be incorporated into the supplier
approval process (clause 220.127.116.11).
Traceability verification is a requirement for each raw material supplier. Therefore, any traceability test
(i.e. because the supplier approval is based solely on a questionnaire) should be designed to test the
raw material supplier’s systems and not to trace every single material they produce. Where a site
purchases multiple ingredients from the same raw material supplier, it is not a requirement to complete
a traceability test for every single ingredient purchased, only to complete the traceability test for each
supplier from which ingredients are purchased.
The frequency of the traceability verification should link to the supplier approval programme; that is, the
traceability is verified on fist approval of the supplier, and then at least every 3 years.
During the BRC audit, the auditor will not undertake a test of raw material suppliers’ traceability systems
but will review the site’s processes and the information received from their raw material suppliers
So, bottom line, there are several accepted ways to document your suppliers traceability program.