What do we need to include in our Traceability Program?

At our facility we manufacture net bags to hold raw produce so we are a food contact packaging manufacturer.  But we also print our own labels.  For traceability do I need to keep records of the lot number for the different inks and things or do I need to just keep lot number records for the ingredients that end up having direct contact with the produce ( such as the plastic pellets used to make plastic net and color additive).  So what I'm asking is do I need lot numbers for things that never come in contact with the item in the bag.

Personally I think it would be a stretch to need to keep lot numbers of the ink.  For the most part you need the lot number for everything that will come in contact with the product...

 I  worked for several different facilities that printed their labels in-house and we never recorded lot numbers. 

Only things that came in contact with the product were recorded. 

At our facility we manufacture net bags to hold raw produce so we are a food contact packaging manufacturer.  But we also print our own labels.  For traceability do I need to keep records of the lot number for the different inks and things or do I need to just keep lot number records for the ingredients that end up having direct contact with the produce ( such as the plastic pellets used to make plastic net and color additive).  So what I'm asking is do I need lot numbers for things that never come in contact with the item in the bag.

unless it smears or migrates through the label there is no risk of contact... unless your customer adds it in on their end... that would be their mistake.

Dear paconmatt,

I suggest it may depend on what ink(s) you actually use. From memory of  previous threads here on the US stance with respect to the FS aspects of printing inks / required validation, the situation was highly ambiguous.

Uncertainty might well encourage traceability.

Rgds / Charles.C