11 replies to this topic

[krissykokoski]

Quick question about lot tracking for products sent direct to consumers.

 

We currently send products direct to consumer from our warehouse.  The product currently goes from manufacturer --> to warehouse --> direct to consumer.  

 

Do we have to track the lots of product we send directly to our consumer?  Or are we covered only tracking the lots sent to the warehouse? 

 

Thanks in advance! 

[kfromNE]

What kind of products do you produce. Are they USDA or FDA. 

[krissykokoski]

Bagged Coffee and KCups 

[MDaleDDF]

In the event of a recall can you account for 100% of your product with your current system?   To me that's the only real question.   

[krissykokoski]

In the event of a recall can you account for 100% of your product with your current system?   To me that's the only real question.   

In the terms of direct to consumer only, we can account for product that gets shipped from manufacture to the DC.  This new DC isn't currently tracking lot #s of product being sent direct to our consumers.  Our previous DC did.   

 

Our other product (big box stores, etc) we do have full traceability.  

[TimG]

Per FDA's CFR

§ 117.139 Recall plan.

For food with a hazard requiring a preventive control:

(a) You must establish a written recall plan for the food.

(b) The written recall plan must include procedures that describe the steps to be taken, and assign responsibility for taking those steps, to perform the following actions as appropriate to the facility:

(1) Directly notify the direct consignees of the food being recalled, including how to return or dispose of the affected food;

(2) Notify the public about any hazard presented by the food when appropriate to protect public health;

(3) Conduct effectiveness checks to verify that the recall is carried out; and

(4) Appropriately dispose of recalled food—e.g., through reprocessing, reworking, diverting to a use that does not present a safety concern, or destroying the food.

 

 

If you have any third-party certifications, they will often have requirements above and beyond FDA. Even working in a grocery distributor who had a very small number of over-the-counter sales we would keep track of who purchased what in case there was a recall of product we sold and needed to contact the consumer.

 

As someone who regularly buys whole bean coffee online to ship to my house, if the company I bought beans from can send me 9 marketing emails (not even exaggerating here) in the first week after purchasing some coffee but can't let me know if the coffee is recalled, it would alienate me something fierce.

Edited by TimG, 12 January 2026 - 03:41 PM.

[krissykokoski]

 

Per FDA's CFR

§ 117.139 Recall plan.

For food with a hazard requiring a preventive control:

(a) You must establish a written recall plan for the food.

(b) The written recall plan must include procedures that describe the steps to be taken, and assign responsibility for taking those steps, to perform the following actions as appropriate to the facility:

(1) Directly notify the direct consignees of the food being recalled, including how to return or dispose of the affected food;

(2) Notify the public about any hazard presented by the food when appropriate to protect public health;

(3) Conduct effectiveness checks to verify that the recall is carried out; and

(4) Appropriately dispose of recalled food—e.g., through reprocessing, reworking, diverting to a use that does not present a safety concern, or destroying the food.

 

 

If you have any third-party certifications, they will often have requirements above and beyond FDA. Even working in a grocery distributor who had a very small number of over-the-counter sales we would keep track of who purchased what in case there was a recall of product we sold and needed to contact the consumer.

 

As someone who regularly buys whole bean coffee online to ship to my house, if the company I bought beans from can send me 9 marketing emails (not even exaggerating here) in the first week after purchasing some coffee but can't let me know if the coffee is recalled, it would alienate me something fierce.

 

 

Thank you! Unfortunately, this DC we are using does not have a third party certification, which gives me many concerns in addition to traceability.  

[TimG]

You mentioned this was your warehouse, but it sounds like it's a DC that handles many different manufacturer/suppliers? Can the ERP being used to track order fulfillment to end consumer track lots along with part#?

[SQFconsultant]

Tim said -- in part- As someone who regularly buys whole bean coffee online to ship to my house, if the company I bought beans from can send me 9 marketing emails (not even exaggerating here) in the first week after purchasing some coffee but can't let me know if the coffee is recalled, it would alienate me something fierce.

 

=================

Agreed, and this was why we changed companies for buying mushroom coffee on a 2-week subscription - they had everything else covered and told us all about how they loved me as a customer, yet when they found out they had foreign debris in their bags of coffee they had no plan to contact me - I found out because of a regulatory listing of recalls.

 

The old adage of "one up and one back" stopped applying when companies and private labels began selling heavily to consumers direct thru drop DC's/3PL's.

 

We had a mushroom coffee client that had their ingredients blended and packaged off-site and shipped to a DC for final shipping to the customer - they were in business for 3 years and had amazed over 500,000 customers when they asked us if they "really had to trace direct to the consumer" They saw it as a headache they didn't need - but started (and are still doing it) doing so and even figured out a marketing agile from it about how wonderful the company is for loving their customers so much.

 

So, yes - it's 100% trace.

[krissykokoski]

You mentioned this was your warehouse, but it sounds like it's a DC that handles many different manufacturer/suppliers? Can the ERP being used to track order fulfillment to end consumer track lots along with part#?

 

It's a 3PL.  Our previous 3PL used our ERP to track, the new 3PL, does not do lot tracking of our orders being sent DTC.  

 

Our leadership are pushing back on the need for this since we don't go to the consumer level with items sent to Walmart, Amazon and Kroger, etc.  

[krissykokoski]

Tim said -- in part- As someone who regularly buys whole bean coffee online to ship to my house, if the company I bought beans from can send me 9 marketing emails (not even exaggerating here) in the first week after purchasing some coffee but can't let me know if the coffee is recalled, it would alienate me something fierce.

 

=================

Agreed, and this was why we changed companies for buying mushroom coffee on a 2-week subscription - they had everything else covered and told us all about how they loved me as a customer, yet when they found out they had foreign debris in their bags of coffee they had no plan to contact me - I found out because of a regulatory listing of recalls.

 

The old adage of "one up and one back" stopped applying when companies and private labels began selling heavily to consumers direct thru drop DC's/3PL's.

 

We had a mushroom coffee client that had their ingredients blended and packaged off-site and shipped to a DC for final shipping to the customer - they were in business for 3 years and had amazed over 500,000 customers when they asked us if they "really had to trace direct to the consumer" They saw it as a headache they didn't need - but started (and are still doing it) doing so and even figured out a marketing agile from it about how wonderful the company is for loving their customers so much.

 

So, yes - it's 100% trace.

 

How would you explain the need for 100% traceability for DTC vs. Wholesaler to say a CFO?  We are able to trace all product we ship out of our 3PLs to customers (Walmart, Amazon, Kroger, etc). I'm struggling explaining it. Any insight? I see you have a lot of knowledge and experience.  

[GMO]

I almost answered this yesterday. I got myself in the same conundrum. "How is it different from selling to a retailer?"

 

How would you explain the need for 100% traceability for DTC vs. Wholesaler to say a CFO?  We are able to trace all product we ship out of our 3PLs to customers (Walmart, Amazon, Kroger, etc). I'm struggling explaining it. Any insight? I see you have a lot of knowledge and experience.  

 

I think it depends on if the wholesaler is your responsibility or ownership or not. UK law, which I know does not apply here, also requires one up one down. So you should have trace to the wholesaler and the wholesaler to the customer because in this case, they can trace as in a retail store unless it's home delivery, you don't necessarily know who has bought the item. (Apart from the widespread use of loyalty cards and apps over here of course.)

 

So I think it is a bit different from retail (potentially) IF you control the warehouse. Or if you don't, it's then a requirement of the warehouse as their "ownership" of food safety of that product only ends at delivery to the consumer's home (apart from issues which can arise later linked back to anything they've done but you know what I mean). So just like a wholesaler delivering to multiple small stores should know who and where everything has gone to, I think the same applies here. 

 

But that's just gut feel, I'm not a US regulatory expert.