Background Paper
Principles of Traceability/ Product Tracing
The Issue: In 2000, “traceability” became a global discussion topic and nations began to impose
unnecessarily prescriptive regulatory standards for tracing products (traceability) to respond to
highly publicized food safety scares. In 2001, The Codex Alimentarius Commission noted that
the matter of “traceability” had been raised in several Codex Committees and Task Forces, and
agreed that it was necessary for Codex to respond in a uniform matter. After several years of
discussion including several physical working groups, following the elaboration of a definition
for traceability/product tracing, the Commission adopted Principles for Traceability/Product
Tracing as a Tool within a Food Inspection and Certification System in 2006. The Codex
Committee on Food Import and Export Inspection and Certification Systems (CCFICS)
recognized that traceability, as a tool that can contribute to the protection of consumers and to
the facilitation of trade. The Principles adopted call for justification and defined objectives, a
full food chain approach, and tracing one step forward and one step back.
Status: When the Principles were adopted by the Commission in 2006, several delegations
expressed the view that guidance for traceability was also needed. In 2008, CCFICS created an
electronic working group to solicit views from delegations on the need for further guidance on
traceability/product tracing. In addition, the Regional Coordinating Committees were asked to
consider the need for further work; the Codex Committee from Europe was interested in further
work but no specific proposals have come forward and the issue has not been on the Codex
agenda since 2011.
Background: In Codex, France first proposed work on traceability in the ad hoc Task Force on
Food Biotechnology, seeking to gain international endorsement of EC proposals for traceability
and labeling of products derived from biotechnology. The ad hoc Codex Intergovernmental Task
Force on Animal Feeding also included a controversial reference to traceability within the Code
of Practice. The Codex Committee on Food Import and Export Inspection and Certification
Systems (CCFICS), noted that “the concept of traceability cuts across a wide range of food
issues,” is not exclusively related to biotechnology, and is relevant to food trade. Within a year,
traceability was being discussed in at least seven different Codex Committees.
The CAC adopted a definition for traceability that had been put forward by CCGP in 2002 as
follows: The ability to follow the movement of food through specific stage(s) of production,
processing and distribution. The Principles ultimately adopted by CAC in 2006 cover the
context, rationale, design and application as a tool for use by competent authorities within the
context of a food inspection and certification system.
Industry Engagement: The initial introduction of traceability within the context of foods for
biotechnology generated significant political controversy. The ICGMA and others had actively
opposed the European regulations requiring the labeling and tracing of products derived from
biotechnology and was extremely opposed to the introduction of traceability within the context
of Codex work. The food industry did not support traceability for the purposes of consumer
information but recognized the broader need for tracking and tracing within the context of risk
management. Industry groups, including ICGMA supported tracing principles that: (1) had a
clearly justified objective related to food safety of fair trade practices; (2) was limited to the steps
in the food chain necessary to achieve that objective; (3) was the least trade restrictive measure
to achieve that objective; (4) take into consideration the costs and benefits and the technical
limitations to assure accuracy and credibility; and (5) allowed necessary flexibility to meet
operational and market needs.