6 replies to this topic

[Sergio Carrola]

Dear Members,

 

I have a question related to the batch number on final product. In most of the goods, a batch number is printed or embossed in the final product. This number usually is eye visible and in almost all cases is a meaning number (concatenation of Julian date, line number, plant identification, time, shift, etc.). My question here is, is there a legal requirement to have a meaning number as batch number on the final product for the consumers? Instead, could we print online only a unique number in the final product that can only be decoded (retrieve all traceability information) by a company system? In case of recall, is there any issue related to it?  I suppose that if we need to do a market recall, we cannot provide via TV or Journals all the printed codes as the list would be huge compared with a meaning number. My question here is really to know if this is regulated or open as long as we can retrieve the traceability info by other means.

Thanks in advance for your clarifications and support.

 

Sergio

[Vladimir Surcinski]

First step would be to look at the regulative of your country (Food Safety Law and other regulative), and next step would be to look at the regulative of countries you are exporting products (if you are exporting). According to my experience i did not come to legal requirements that clearly states how your batch/LOT number should look. It is always mentioned that company must have the system of tracking each product and company must assure clear traceability. Also company must assure that in case of nonconformity product, process of withdrawal/recall is performed.  

 

So, you must have system and batch number, but u can use any that you think is best or easiest for your system of production. 

 

I hope i helped. 

[Foodflavour]

I agree with Vladimir but one of the main reason for batch code on products is for ease of tracing in the event of any food safety or any other reason for a recall.

[moskito]

Hello,

 

there is no regulation in the EU how a code/lot number has to be. It is up to you whether you want to create a "speaking" number or a number without any relation as long as you are able to perform traceability successfully and if you are certified you are able to handle complaints, to run your continous improvement process .... (-> IFS, BRC etc.)

I am not aware that there is a special regulation on that in any country we are exporting (> 80 countries)

 

Rgds

moskito

[Sergio Carrola]

Thanks a lot for your answers, it helps me.

[Charles.C]

HI All,

 

Out of curiosity where is the EC regulation that states that all imported products must have a "batch number" ?

 

Or by batch number did you simply mean manufacturing date ?

[lecoutree]

HI All,

 

Out of curiosity where is the EC regulation that states that all imported products must have a "batch number" ?

 

Or by batch number did you simply mean manufacturing date ?

 

In the Framework (EC) 1935/2004 (http://eur-lex.europ...0090807&from=DE) in Article 17 Traceability it is stated:

1.  The traceability of materials and articles shall be ensured at all stages in order to facilitate control, the recall of defective products, consumer information and the attribution of responsibility.

2.  With due regard to technological feasibility, business operators shall have in place systems and procedures to allow identification of the businesses from which and to which materials or articles and, where appropriate, substances or products covered by this Regulation and its implementing measures used in their manufacture are supplied. That information shall be made available to the competent authorities on demand.

3.  The materials and articles which are placed on the market in the Community shall be identifiable by an appropriate system which allows their traceability by means of labelling or relevant documentation or Information.

Usually you would fulfill this by using a batch number. But other possibilities may exist.

 

Best regards

Andy