Traceability contact with food

It must be clear for the control authorities that Article 17 represents a challenge for the operators of the food contact materials and articles chain not only to align, harmonise and deepen their internal and inter-chain system of product tracing and recall, but also to control appropriately, identify and penalise illegal behaviour. As outlined in section 4.2.1, there are three types of food contact materials and articles for which traceability must be ensured (i) materials and articles already in contact with food, (ii) those manufactured for food use but not yet in contact with food at the retail stage, and (iii) those that can reasonably be expected to be brought into contact with food or to transfer their constituents to food under foreseeable conditions of use. The traceability for these three categories can be different, in particular in relation to the traceability of food set forth by Article 18 of 178/2002/EC. 

In relation to the previous two sections, this is not a separate category of food contact materials and articles when it comes to traceability information and its flow in the supply chain. The peculiarity here is the point at which the material or article is identified as coming into contact with food, and the fact that this contact can be indirect. Therefore the starting point of the traceability chain can be quite different from that of more traditional food contact materials and articles, but the end point still is the retailer, at which point the material is either in contact with food or not. Thus the previous two paragraphs apply, depending on the circumstances. 

This also implies that, in the opposite direction, the material or article can be traced from any point in the chain down to the retailing point. In other words, if traceability can be described as the possibility to trace back from finished goods shipments to raw material lots, this should not neglect that there is a need to trace forward from raw material lots to identify all finished goods shipped. In fact traceability was introduced primarily for ensuring that defective food contact materials are identified and withdrawn from the market, in particular as far as compliance with the applicable legislation is concerned. If a given raw material is found in violation of the law, or such as to impair safety of the finished product, traceability systems shall be such as to allow withdrawal of all other finished product in which the concerned raw material has been used. To achieve this objective both levels must function properly. 

Traceability systems already exist in the food contact material distribution chain, mainly to address quality problems that may arise with use. ISO-certified companies, as well as companies operating using Good Manufacturing Practice, not only adopt these systems internally, but also require their suppliers, service companies and manufacturers to use them, so that traceability is a common and widespread feature of food contact materials in the European... 

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