It’s Time To Master Traceability Before It Masters You!

Hey FoodSafe Community,

This week, we're diving into Traceability—a term that often sends shivers down the spine of small food producers. With new supply chain regulations tightening across the UK, EU, and US, ensuring robust traceability systems has never been more critical.

I know we touched on some of this last week, but I really want to make sure this topic hits home, because of what’s coming down the pipe! So, let's break down what's changing, why it matters, and how you can stay ahead before the regulators come knocking.

Industry Spotlight – The Global Crackdown on Traceability

What's Happening?

Regulators across the UK, EU, and US are intensifying their focus on supply chain traceability. The ability to prove the origin of every ingredient in your products is becoming paramount, with significant compliance implications for those who fall short.

Here's why regulators are cracking down:

• Food fraud is on the rise – UK retailers saw a 28% increase in fraudulent products in 2024.

• Recalls are becoming costlier, imposing substantial financial burdens on the UK economy – The average recall in the UK now costs food businesses £350,000. ​

• Regulators demand speed – In the US, if you can't trace any batch of ingredients within 24 hours, you could face enforcement actions.

The Key Regulations You NEED to Know

UK & EU: Enhanced Traceability Requirements

The European Union has established itself as a leader in supply chain traceability, implementing robust regulations and technological advancements to enhance transparency and accountability within the agrifood sector.

It is tightening its grip on supply chain traceability, making it non-negotiable for food producers. Recent regulatory shifts demand greater transparency and accountability from every business handling food products, from small artisanal producers to large-scale manufacturers.

• Digital Product Passports (DPP): The upcoming Ecodesign for Sustainable Products Regulation (ESPR), set to enter into force on July 18, 2024, introduces the concept of Digital Product Passports. These passports aim to provide detailed information about a product's sustainability and traceability, accessible through digital means. The implementation will begin in 2026, with full enforcement expected by 2030.

• E-Labels for Wine Products: As of December 8, 2023, mandatory digital labelling has been implemented for wine bottled after this date. This initiative allows consumers to access comprehensive product information digitally, reflecting the EU's commitment to enhancing transparency through technology. ​

US: FSMA Rule 204 Requires Real-Time Traceability

The FDA's Food Safety Modernization Act (FSMA) Rule 204 mandates that businesses handling foods on the Food Traceability List (FTL) maintain detailed records to trace the movement of these foods through the supply chain. Compliance with FSMA 204 is required by January 2026.

What This Means for You

If you're a small food producer in the UK, EU, or US, this means:

1. You MUST have a batch tracking system –

2. You need to be audit-ready 24/7 –

3. You can't rely solely on suppliers –

What You Should Do NOW

1. Audit your current traceability system – Ensure your supplier records are up to date and that you can verify the origin of your ingredients.

   • Make sure every supplier provides detailed batch records.

   • Keep digital copies of supplier certifications in one place.

   • Create a recall plan that allows you to trace a faulty ingredient in minutes, not days.

   Use platforms like FoodSafe to keep everything organised, accessible, and audit-ready.

2. Future-Proof Your Labels

   New E-labelling requirements for wine and other food products mean you should start considering QR codes or digital tags for:

   • Nutritional info & allergens

   • Sustainability claims

   • Batch tracking & provenance data

   Even if your product isn't affected yet, major retailers are starting to favour brands with digital labelling transparency.

   Look into digital labelling solutions like GS1 Smart QR codes, which retailers like Tesco and Carrefour are already piloting.

3. Digitise your batch records – Paper logs are no longer adequate.

4. Prepare for unannounced audits – Regulators are conducting more surprise inspections, especially in the UK.

Regulation Radar: What's Coming at You NOW

FSA's New Allergen Rules Target Small Food Producers (UK)

The Food Standards Agency (FSA) is cracking down on allergen labelling, particularly targeting small food producers who may not have digitised or structured allergen tracking systems in place.

What’s Changing?

• By April 2025, all food businesses—including micro and small-scale producers—will be required to maintain structured allergen records, moving away from ad-hoc handwritten logs.

• Increased inspections and enforcement fines of up to £5,000 for businesses failing to provide accurate allergen tracking.

• Stricter documentation requirements for food sold loose or pre-packaged, ensuring ingredient cross-contamination risks are clearly identified.

What This Means for You:
If you’re a small food business, BRCGS, SALSA, or ISO 22000 certified, expect higher scrutiny during audits. You need to be able to prove traceability of all allergens from supplier to final product.

How to Stay Compliant:
1. Digitize allergen records—spreadsheets aren’t enough when auditors ask for proof of changes over time.
2. Verify supplier allergen declarations—don’t assume ingredients haven’t changed.
3. Train staff on new allergen risks and update internal procedures.
4. Use a food safety management tool (like FoodSafe!) to maintain version-controlled allergen logs.

EU Mandates New Sustainability Labelling for Food Products

The European Commission is tightening sustainability reporting, requiring all food and beverage producers to provide transparent environmental impact labels on packaging and marketing materials.

Key Changes:

• Mandatory carbon footprint disclosure for packaged food products sold within the EU.

• Stricter greenwashing enforcement—misleading sustainability claims could result in fines of up to €500,000.

• Increased focus on supply chain emissions, meaning businesses need accurate traceability of ingredient sourcing.

What This Means for You:
If you operate within the EU market, it's essential to ensure that any environmental claims about your products or services are substantiated with clear, scientific evidence and have undergone independent verification. Non-compliance could lead to penalties, damage to your brand's reputation, and loss of consumer trust.

How to Stay Compliant:

1. Conduct Comprehensive Environmental Assessments: Utilize recognized scientific methods, such as Life Cycle Assessments (LCAs), to evaluate and substantiate your environmental claims. Ensure that these assessments are thorough and consider all stages of your product's life cycle.

2. Engage Accredited Verification Bodies: Before making environmental claims public, have them verified by independent and accredited bodies to ensure compliance with the directive's requirements.

3. Avoid vague eco-claims like “environmentally friendly” unless backed by verifiable data.

Industry Pulse: Risks & Recalls

Undeclared Allergens in Popular Condiments

Baxters Food Group issued an urgent recall for their Sliced Gherkins Crunchy and Sweet due to undeclared mustard, posing serious health risks to individuals with mustard allergies.

Lesson? This incident highlights the necessity of meticulous labelling practices. Small producers must ensure that all potential allergens are clearly declared on product labels to prevent consumer harm and avoid costly recalls.

Pancake Mix Pulled Due to Undeclared Milk Allergen

The Quaker Oats Company has pulled 10,000 cartons of Pearl Milling Company's Original Pancake & Waffle Mix from shelves due to an undeclared milk allergen. This oversight poses a serious health risk to individuals with milk allergies, leading the FDA to classify the recall as Class I, indicating a high risk of adverse health consequences or death.

Lesson? Implementing stringent quality control measures and regular label reviews can prevent such errors, safeguarding both consumer health and your brand's reputation.

Rising Trend in Food Recalls

There has been a noticeable increase in food recalls in early 2025, affecting everyday items from smoked salmon to broccoli. ​

Lesson? The uptick in recalls emphasises the necessity for small producers to stay informed about potential hazards and proactively enhance their food safety protocols to protect consumers and maintain brand integrity.

Mastering Traceability with FoodSafe!

Imagine this: A supplier mix-up sends you a bad batch of ingredients, and now an auditor wants a full traceability report—yesterday.

Panic mode? Not if you're using FoodSafe’s Traceability Module.

If you’ve ever lost a batch record, struggled to trace an ingredient, or worried about recall readiness—this is the video you don’t want to miss.

Retail Spotlight: Supermarkets Embrace Small Producers

In 2025, UK supermarkets are increasingly collaborating with small and local producers to diversify their offerings and support local economies. This trend not only enriches product ranges but also strengthens community ties. Here's how major retailers are engaging with small producers and whether they're currently seeking new suppliers:​

Co-op's Expansion in Convenience Sector

Co-op plans to open 75 new stores across the UK in 2025, focusing on accelerating growth in the convenience sector. This expansion includes up to 25 Co-op estate stores and 50 new franchise stores, with the first openings scheduled for early 2025. Co-op is actively seeking new freehold and leasehold spaces, indicating opportunities for suppliers to partner with these new outlets. ​grocerygazette.co.uk

Sainsbury's Acquisition of New Supermarkets

Sainsbury's has acquired 13 new supermarkets from Homebase and Co-op, aiming to launch around 20 new supermarkets within the next 12 to 15 months. This expansion includes adding approximately 400,000 sq ft of supermarket trading space, bringing more consumers within a 10-minute drive of Sainsbury's supermarkets. Sainsbury's is also expected to open around 25 new convenience stores per year, indicating potential opportunities for small producers to become suppliers. ​grocerygazette.co.uk

Opportunities for Small Producers

The expansion strategies of these supermarkets indicate a strong interest in diversifying product offerings and enhancing local sourcing. Small producers looking to collaborate should consider reaching out to these retailers' supplier relations departments to explore potential partnerships. Attending industry events and supplier open days can also provide valuable networking opportunities to establish connections with these expanding retailers.​

By aligning with the growth initiatives of major supermarkets, small producers can expand their market reach and contribute to the rich diversity of local products available to consumers.

Hot Tip of the Month: The 5-minute Traceability Test

Would your business pass an unannounced traceability audit? Try this:

Steps to Test Yourself:

1. Find a product you made last month.

2. Identify the batch number of the key ingredient.

3. Locate the supplier records and delivery logs for that batch.

4. Verify when it was used in production and match it to the final product batch.

5. Ensure your documentation is complete and accessible within 5 minutes.

If any of these steps take too long, you have a traceability gap that could put your business at risk in an audit!

Tool of the Week: Free FSA Labelling Decision Tool

Check out the FSA’s Allergen and ingredients food labelling decision tool !

Use this tool to find out more about the different requirements for food labelling and what your business needs to do.

The Safety Scoop Community – Your Turn!

We love hearing from you.

Until next time—stay compliant, stay ahead, and keep making great food!

Paddy

Founder & CEO

The FOODSAFE Team

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