It is a requirement of ISO22000 to ensure the batch traceability of Raw materials used with the manufacturing process, so in the event of an issue, say at a suppliers, we can then identify what batches of our finished product contained the effected batch of raw material.
However, what would be the expectations where the finished product contained food safe, recycled / reclaimed materials? the same traceability, back to the original raw materials or even supplier cannot possibly exist once in the Recycled stage of a process..
The recycling process cannot identify the specific batch details for the raw materials used, so the end user of the recycled product would not be able to maintain the link back to the initial, virgin source either.
What would we need to do, as a user of the recycled material, to satisfy the requirements of the standard in terms of recording the batch details where it includes the use of recycled materials?
Would we just need to record that a particular batch of finished product contained "re-cycled" material, and perhaps the date it was processed or would it need to go back to a specific source / identification?
Any advice would be gratefully received.