The Importance of Source Tracing in Production Systems

 We may define these aspects as two sides of the same coin: source tracing may not exist 
without a traceability system and, at the same time, the traceability system is not efficient if it 
doesn’t allow source tracing. 
 
1.2 REFERENCE RULES 
Is source tracing a voluntary or mandatory practice? 
The concept of source tracing is embedded in and adopted by Legislative decree 155 of 1997 
obliging the agricultural foodstuff producer – in art. 3 paragraph 4 – to withdraw from the 
market all products presenting an immediate health risk. 
This prescription implies to indicate a number on the package to be consumed. 
According to EC regulation 178/2002 all food and beverage operators must be able to identify 
the provider of any substance supplied to them and intended to be a part of food. 
Namely: 
“Article 18 
Source tracing 
Source tracing is prescribed throughout all the production, transformation and distribution 
steps of foodstuffs, feeds, edible livestocks and whatever other substance intended or apt to 
enter the composition of a foodstuff or feed. 
Food and feed production operators must be able to identify whoever supplied them a 
foodstuff, feed, an edible livestock or any other substance intended or apt to enter the 
composition of a foodstuff or feed. For this purpose operators must arrange all the systems 
and procedures allowing the competent authorities to obtain – upon request – the relevant 
information. 
Food and feed production operators must arrange systems and procedures allowing them to 
identify the firms receiving their products. The relevant information is made available to the 
requesting competent authorities. 
The foodstuffs and feeds introduced in the Community Market, or which may be there 
introduced must be properly labelled or identified in order to favour their source tracing - 
through pertaining documents or data - according to the requirements set for the matter by 
more specific prescriptions. 
Paragraph one of article 18 defines the extension of source tracing: 
The object is foodstuffs, feeds, farm produce and any other substance bound to enter the 
foodstuff or feed ( such as ingredients, additives); 
The obliged subjects are all the operators coming in contact with the above-mentioned 
materials, along the whole supply-chain (primary farming, transformation, distribution). 
  
3 
 
 The second paragraph sets the first obligation: to be able to identify one’s suppliers of raw 
materials, in other words who supplied what. The operator is not required to trace back the 
origin of the raw material, but to simply identify the entity who has supplied it: this could be a 
farmer, a collection centre, a first-process transforming plant, as well as a dealer, a broker, an 
importer. 
The regulation does not prescribe the operator to adopt specific means: collecting and 
keeping instruments for the above-mentioned information is therefore left to the individual 
choices of the obliged subjects. 
The obligation is instead signified in terms of result which the obliged subjects must be able 
to supply - apart from the adopted procedures – to the competent (health and control) 
authorities requesting information about their stocks: supplier’s name and address; type of 
good received. 
The third paragraph of article 18 defines a second obligation: to be able to identify the dealers 
to whom their products have been delivered, in other words who received what products. The 
operator is requested to identify his direct customer, excluding the final consumer: he is not - 
on the other end - prescribed to know the product’s subsequent transformation/marketing 
steps down to the sale/final consumption. 
The second obligation is also signified in terms of result; the obliged subjects must be able to 
provide – upon request by the competent authorities – essential information concerning their 
product sales: buyer’s name and address (excluding consumer),type of products sold. 
The fourth paragraph finalizes dealing with the subject by recalling the need - for the sake of 
source tracing – to identify the foodstuffs and feeds which are introduced, or are about to be 
introduced,  in the common Market. 
The fifth and last paragraph of article 18 specifies the procedure to be exclusively adopted in 
order to introduce more rules in terms of source tracing: Community rules for implementing 
the principles contained in the (EC) Regulation 178/2002, limited to specific sectors. 
The norm explicitly rules out the introduction of national rules regarding source tracing: 
should the political authorities be interested in integrating the practical application of the 
rules of source tracing,  they shall be obliged to activate the apposite procedure. 
Any national or regional set of rules apt to impose further obligations than those set in article 
18 of EC regulation n° 178/2002, will be considered in direct contrast with the said 
regulations. Packaging materials are not included in art. 18 of the said regulation, even those 
coming in contact with the food product. The duty, falling upon the operators, is to record 
provisions of incoming raw materials and deliveries of outgoing products: nature and amount 
of raw material/product, name and address of supplier/customer, date of receipt/delivery. 
Operators may also save the said information by means of their usual recording systems, 
provided they are able to transfer them to the competent authorities: the duty may be 
consequently fulfilled, for instance, by saving both the documents attached to the incoming 
raw materials, and those dispatched with the delivered products. 
EC rules n° 178/2002 do not impose to operators the so called “internal source- tracing”, or 
reconstruction of the route that every raw material or substance employed in the transforming 
process has followed inside the plant. 
  
4 
 
 The rules do not then indicate the must of an internal traceability, in other words the 
reconstruction of the entire route inside the plant is not necessary, but the duty to identify 
who supplied what and what has been supplied to whom is sanctioned. Therefore, what has 
become mandatory through EC rules 178/2002, is the sole external traceability apt to detect 
the transfer of liability bound to the property transfer. 
In some sectors, such as the meat, eggs, wine, shellfish and fish, supply chain source-tracing 
is mandatory, whereas in other sectors it is possible to acquire a quality certification through 
voluntary rules. 
Norm UNI 10939 “Source-tracing system in the agro-industrial supply chains – General design 
and operation principles “ sets the general principles for the design and actuation of a source-
tracing system in agro-industrial supply chains. It is an outline norm defining the standards 
and specifying the requisites for the operation of a supply chain source-tracing system 
whenever the history of a product must be documented and the specific liabilities by 
identifying and recording the material flows and organizations contributing to the making, 
marketing and supply of an agro-industrial product. 
The norm does not intend to enforce the uniformity of the supply chain source-tracing 
methods by associating the word “supply chain source-tracing” to the product/s or the major 
component/s. As conceived, this norm somewhat intends to leave to the parties the burden to 
define the breadth ( meaning beginning and end of the supply chain) and depth (meaning 
number of products and components) of the agro- industrial supply chain, since the design 
and operation of a supply chain source-tracing system are influenced by the product for which 
the documented supply chain is meant to be defined and by the necessity to observe the 
legislation and compulsory rules. 
The norm sets, as first act for the single organizations, to share such aspects as the products’ 
or the major components’ definition, the flows of involved materials, the separation and 
registration methods of the product as much as needed. The second step consists in ensuring 
the proper operation of the supply chain source-tracing system by any involved organization, 
though the definition of a control plan. 
The norm also reserves special attention to training, sensitising and involvement of the 
personnel appointed by the participating organizations, given the significance that the 
awareness of the importance of one’s own role can play in a source-tracing system. 
Once the system has been established, a periodical review is necessary to evaluate its 
effectiveness. 
The norm also provides for the system to be documented in order to acquire its updated, filed 
and easily accessed registration. 
Another voluntarily applicable norm is the UNI 11020 dated 2002 Source-tracing system in the 
agro-industrial supply chains – General design and operation principles, this document 
defining the requirements to be met by each firm for the correct management of source-
tracing inside itself. The application of this norm cannot leave out the previous one: UNI 
10939. The former inserts in fact upon the latter in order to provide each agro-industrial firm 
with to source-trace batches of materials and finished products. 
  
5