Traceability of goods is the ability to track goods and trace their history; trace a product through the whole or partial supply chain - from raw materials obtained via transport, storage, processes, distribution - to sale, or internally in one of the steps of the chain, through the production process. Traceability of goods is important from two perspectives:
The lawmaker has clearly described its objectives in the legislation. However, the legislation doesn't specify how the objectives are to be met. In addition, the legislation is also 'technology neutral'. This means that the regulator doesn't prescribe the technologies to be used. Manufacturers may choose the traceability system which they deem most appropriate in relation to their products and their manufacturing and distribution system. The harmonisation legislation however does prescribe the minimum information to be provided.
Manufacturers are obliged to:
The information must be displayed on the product. If this is not possible then the information is added to the packaging or to an accompanying document.
This would be the case when the size and/or the nature of the product makes the indication illegible or technically impossible. Aesthetic reasons do not fall under the exception.
Examples of products with this exception are:
You are considered as an importer when you place products from outside the EU onto the EU market. Importers are obliged to:
The term 'contacted' is important for the authorities. It however doesn't necessarily mean the actual address where the importer is established, it can also be the address of a customer service.
Displaying a website is allowed, but does not replace the contact address: it's considered additional information.
Economic operators have the obligation to be able to identify any economic operator who has supplied them with a product and to whom they have supplied a product. The obligation is set for a period of 10 years. The consumer (end-user) is not considered an economic operator. The legislation doesn’t provide rules on this obligation. It is consequently advised to comply to this obligation through relevant documentation, such as invoices. It is thus advisable to retain this information for a period of at least 10 years. These 10 years may be longer than required under accountancy legislation…
In order to be able to identify a specific product, the product must, as a rule (see below), bear a type-number, batch number, serial or model number or another element allowing the product to be identified.
The manufacturer is given the freedom to choose the identification method most suitable to the product, as long as traceability is ensured.
Yes, in case of a recall or withdrawal from the market, all products with that specific identification must be recalled or withdraw. The better the identification, the least products affected, the lesser the costs will be.
The abbreviation UFI is short for Unique Formula Identifier. The UFI is an obligation for hazardous mixtures placed on the market.
Read more on this in the dedicated Compliance Clip.
What information should be included on the product packaging and labelling in order to comply with applicable legislation? Through our label check service, you send us the packaging, artwork & manual per country, we will check applicable legislation. More information via this link or e-mail.