Lot traceability in food distribution: getting your systems recall-ready
When a supplier flags a problem with a lot, the question is immediate: which customers received it, how much and when? A business answering from paper packing slips and spreadsheets loses valuable time and risks missing a customer.
In Canada, the Safe Food for Canadians Regulations require many food businesses to trace food one step back and one step forward, and the Canadian Food Inspection Agency (CFIA) sets out those requirements. In the United States, the FDA has adopted a rule on additional traceability records for certain foods.
This article isn't legal advice. It turns those principles into operational decisions: what data to capture, when, in which system, and how to check that the chain holds up during a mock recall.
Published · By Shopflow
- Category:
- Orders and inventory
- Format:
- Article
- Goal:
- Understand
What the rules expect you to be able to trace
According to the CFIA, a regulated business that provides food to another person must prepare and keep documents that identify the food: its common name, a lot code or other unique identifier, and the name and principal place of business of whoever manufactured, packaged or labelled it. Those documents trace the food one step back, with the date received and the supplier's name and address, and one step forward, with the date and the recipient's name and address.
The CFIA specifies that these documents must be kept for two years and be accessible in Canada. On request, they must be provided in English or French within 24 hours, or within a different time frame set by the Agency. If provided electronically, they must be a single plain-text file that standard commercial software can use. Retailers selling to consumers have different obligations.
If you sell into the United States, the FDA's food traceability rule applies to products on its Food Traceability List. It's built around critical tracking events and key data elements to record. Check the FDA page for the current compliance date and whether your products are covered.
Your obligations depend on your activities, products and markets. Have a qualified professional confirm your situation before you finalize your procedures.
Define your lot code and when it's captured
The CFIA notes that the regulations don't prescribe a lot code format. A code can be numeric, alphabetic or alphanumeric and must identify a lot produced under the same conditions, such as the date, shift or production line. The more specific the lot, the narrower the scope of a recall can be.
For a distributor, the practical question is where the lot enters the system. Receiving is the key moment: the supplier's lot and best-before date need to be recorded with the goods received. Decide whether you keep the supplier's lot or create your own identifier, and maintain the cross-reference between the two.
Manual entry multiplies the risk of errors. Ask whether your receiving tools can scan the codes printed on cases and what happens when a case arrives without a readable code.
Apply FEFO without losing the link to the lot
FEFO, or first expired, first out, means picking the lot with the nearest expiry date first. It differs from FIFO, which follows the order stock was received. For perishables, the date matters more than when the product arrived.
Spell out the rules around FEFO: minimum remaining shelf life some customers require, lots on hold pending inspection, allowed exceptions and who can approve them.
Your system needs to record the lot actually picked, not just the one it suggested. If a picker grabs a different case, forward traceability has to reflect what was shipped.
Tie every stock movement to a lot
Traceability often breaks between receiving and shipping: one transfer, repack or return recorded without a lot is enough to leave a gap. Every movement has to carry the lot identifier.
| Event | Data to record | System that captures it | What to check |
|---|---|---|---|
| Supplier receipt | Product, lot, best-before date, quantity, supplier, date | Receiving or warehouse | Match against the purchase order |
| Warehouse transfer | Lot, quantity, origin, destination, date | Inventory management | Lot preserved on arrival |
| Processing or repacking | Input lots and new lot created | Production or warehouse | Link between input lots and output lot |
| Picking and shipping | Lot picked, quantity, customer, address, date | Order fulfillment | Actual lot, not suggested lot |
| Customer return | Lot returned, reason, decision | Customer service and warehouse | Restocked or written off |
| Disposal or downgrade | Lot, quantity, reason, date | Operations | Stock variance explained |
If you also sell to consumers online or in store, keep those sales separate from shipments to businesses such as restaurants or grocers. The CFIA describes different obligations for retail sales.
Write your recall procedure before you need it
Recalls go badly when people discover their roles at the same time as the problem. Decide in advance who makes the call, who contacts customers, who holds the stock and who communicates with the authorities.
- Identify the affected lot or lots and any lots made from them.
- Hold stock in every location and pull the product from online sale.
- Extract the list of customers who received it, with quantities and ship dates.
- Notify customers using a prepared message template.
- Arrange returns or disposal and keep proof.
- Document each step and every decision made.
Make sure the extract can be produced in the format the authority requests, without manually merging several files.
Test the chain with a mock recall
Pick a real lot received a few weeks ago. Ask your team to trace it back and forward, and time how long it takes. Then reconcile the quantity received with what was shipped, is still in stock, was returned or was destroyed.
Variances expose the weak spots: lots not captured at receiving, unrecorded substitutions, returns put back into stock without a lot. Fix the cause in the process, not just the data.
Your checklist
Reliable traceability depends less on a tool than on rules applied to every movement. Use this list to review where you stand with your teams.
Your decision list
- Confirm the requirements that apply to your operations in Canada and the U.S.
- Define your lot code and its cross-reference to the supplier's.
- Capture the lot and best-before date at receiving.
- Set FEFO rules and record the lot actually picked.
- Preserve the lot through transfers, processing, returns and disposal.
- Write the recall procedure and assign owners.
- Schedule regular mock recalls and fix the root causes of variances.
Where Shopflow fits
Shopflow's Food & Beverage page describes lot and expiry tracking, FEFO logic and recall readiness. The FAQ on the OMS & Inventory page mentions tracking by serial number, lot or expiry date. These descriptions aren't a certification of compliance: test your own scenarios for receiving, recording the lot actually picked, extract formats and the connection to your warehouse system.
Sources consulted
- Canadian Food Inspection Agency: Regulatory requirements: Traceability for food (opens in a new tab)
- Canadian Food Inspection Agency: What to consider when selecting a lot code to meet traceability requirements under the Safe Food for Canadians Regulations (opens in a new tab)
- U.S. Food and Drug Administration: FSMA Final Rule on Requirements for Additional Traceability Records for Certain Foods (opens in a new tab)