Food traceability maturity · Regulation (EC) No 178/2002
Your traceability, measured against Regulation 178/2002 and turned into an action plan.
10 themes, a 5-level scale. And the action that moves each level to the next.
The framework’s 10 themes, already written from L1 to L5. One company, one business unit, or 300 at once.
Food traceability maturity · Regulation (EC) No 178/2002
10 themes, 5-level scale.
Nordhavn Industries
53 / 100
They measure their maturity with Datamensio
An example
This could be your situation.
Take one company as an example: three sites, three spreadsheets, no shared answer.
Nobody can consolidate.
Nordhavn Industries, 2,400 people in Hamburg, Lyon and Porto. A client asks where the group stands. Each site answers in its own spreadsheet, with its own scales.
Three weeks, a single base.
One Regulation (EC) No 178/2002, Article 18 (traceability), Articles 19 and 20 (withdrawal and recall) assessment launched across all three sites at once, from the managers’ interview notes. The framework was already written, its 10 themes and levels L1 to L5 too.
Two costs avoided before being committed.
A score of 53 out of 100, with the gap concentrated on three themes. The AI companion spotted that two actions duplicated those of another audit. The committee report took one sentence to request.
What it saved them
- 3sites measured on the same base, instead of three questionnaires to reconcile
- 2duplicate actions caught before the spend
- 1committee report, with no manual rework
These figures are an example. They could be yours.
The standard imposes processes. Datamensio says where you stand.
01
The framework is already written
Themes, questions and levels L1 to L5, all written. You do not start from an empty spreadsheet.
02
The score lands the same day
Online, by self-assessment link or in interview. Theme by theme, comparable over time.
03
The gap becomes a costed plan
Every step up carries its action. The AI prioritises on expected effect, not on the order of the standard.
04
Progress can be demonstrated
Campaign after campaign, against your target and against your own past. That is what your board asks for.
The maturity scale
One level, the next, and the action that links the two.
It is this mechanism, one level, the level above, and the action that links them, that turns a finding into a trajectory.
Do you run upstream and downstream traceability exercises, and is reconstruction time measured?
- N1
No exercise is carried out. The ability to reconstruct a flow has never been verified outside an actual incident.
- N2
Exercises take place occasionally, at the request of a customer or an auditor, with no set frequency or formal report.
- N3
Exercises are planned, cover both upstream and downstream, and result in a written report stating the reconstruction time and quantities traced.
- N4
Exercises are unannounced, timed, include a mass balance and involve logistics providers. Gaps are handled through a tracked action plan.
- N5
Scenarios are revised in light of sector incidents and alerts received, results are compared across sites and over time, and feed into management review.
Action to move from L2 to L3
Schedule two exercises a year in the quality plan, one upstream and one downstream, using a report template that requires reconstruction time, quantities traced and the gap to mass balance, then present the results at the monthly quality review.
« With Datamensio, we meet our objectives far more efficiently. The ERDF inspection services and our supervising ministry particularly appreciated an approach that gives them reliable data. »
Director, CCI 94CCI Île-de-France
« We believe this is the most suitable solution to scale our transformation project and measure impact according to our needs. »
Maja SucekChief Operating Officer, Interreg Danube
Rarely on its own
Frameworks combine. Put several together to cover your business, or have the AI write yours.
Take your first measurement
What this framework covers
Regulation (EC) No 178/2002 lays down the general principles of food law and establishes the European Food Safety Authority. Its Article 18 sets out the so-called one step forward, one step back rule: every operator must be able to identify the businesses that supplied it with a food, feed or a substance intended for incorporation, and those to which it supplied its own products. Articles 19 and 20 require the immediate withdrawal of a non-compliant product, its recall from consumers once it has already left the supply chain, and prompt notification of the competent authority. Foods must be labelled or identified in a way that facilitates this traceability.
In practice, the obligation is short to read and hard to sustain. The text sets no format, no fixed response time, no lot granularity: it is left to the enforcement authorities to judge whether a system is adequate. Hence questions that quality teams genuinely ask themselves. What is the smallest unit you can trace, the supplier batch or the pallet received? How long does it take to draw up the list of customers who received a suspect lot, and is that list complete or reconstructed by hand? Does traceability data remain accessible once a supplier, a logistics provider or the ERP has changed?
One confusion comes up often. Regulation 178/2002 imposes external traceability, from the direct supplier to the direct customer, excluding the final consumer. It does not impose internal traceability, meaning the link between incoming and outgoing lots at a given site. Yet it is precisely this internal traceability that determines how precise a withdrawal can be: without it, a single suspect raw material lot forces a recall of the entire production run for the period. Private schemes (IFS, BRCGS, FSSC) and enhanced traceability requirements for certain products of animal origin close this gap, but the obligation of result in the event of an incident remains with the operator.
An official inspection concludes with a finding of compliance or non-compliance. A maturity assessment answers a different question: what level of control does your system actually operate at, and what specific action moves it forward. A traceability exercise run once a year at a customer’s request is not at the same level as an unannounced upstream and downstream test, timed, documented, whose gaps feed an action plan tracked at management review. The scale makes this difference visible and comparable across sites.
In Datamensio, the framework is ready to use and fully adaptable. AI adjusts the themes, questions and levels to your activity, be it processing, trading, logistics or distribution, or builds a version from your own procedures and exercise reports. The roadmap then groups gaps by workstream, with a cost and a timeframe attached to each action.
Reference standard: Regulation (EC) No 178/2002, Article 18 (traceability), Articles 19 and 20 (withdrawal and recall)
The themes assessed
Governance and traceability scope
Formal procedure, scope of products and sites covered, designation of responsible persons, alignment with the food safety management system.
Supplier identification (upstream)
Recording of direct suppliers, nature and volume of products received, receipt dates, supplier lot numbers, accompanying documents.
Customer identification (downstream)
Recording of direct customers excluding the final consumer, quantities delivered, dispatch dates, lot references linked to each delivery.
Internal traceability and lot management
Link between incoming and outgoing lots, rules for building and splitting lots, traceability of rework, surplus and repackaged products.
Labelling and unit identification
Lot marking on sales units and logistics units, legibility, coding, consistency between physical labels and system records.
Information systems and records
Data storage medium, ERP or spreadsheets, retention period, integrity, accessibility in the event of a system change, backup and degraded mode.
Withdrawal, recall and notification of authorities
Withdrawal and recall procedure, trigger criteria, consumer recall decision, notification to the competent authority, public communication.
Traceability exercises and tests
Frequency of upstream and downstream exercises, unannounced nature, measured reconstruction time, mass balance, handling of identified gaps.
Control of suppliers and service providers
Contractual traceability requirements, specifications, assessment of logistics providers and subcontractors, products imported from third countries.
Crisis communication and continuous improvement
Internal alert chain, identified contacts day and night, post-incident lessons learned, procedure review, indicator tracking at management review.
A short version of the framework is available for the online self-assessment.
Frequently asked questions
Can Regulation 178/2002 be certified?
No. It is a directly applicable EU regulation, enforced by the competent authorities under Regulation (EU) 2017/625. The assessment measures your level of control and prepares you for official inspection or private audit, it does not issue any certificate.
What is the difference between this assessment and a compliance audit?
An audit concludes with a finding of non-compliance or compliance against each requirement. The assessment places your practices on a maturity scale and points to the action that moves you to the next level. The two are complementary: the assessment prepares and prioritises, the audit validates.
Does the regulation require internal traceability?
Article 18 requires external traceability, direct supplier and direct customer. Internal traceability is not explicitly required, but without it a withdrawal becomes imprecise and costly. The framework assesses it as a theme in its own right, since it determines the real performance of the system.
How long does the assessment take?
The short version can be completed in around thirty minutes by a quality manager. The full version, run collaboratively with logistics, production and information systems, typically takes one to two weeks, most of the time being spent gathering input from the teams.
Can the framework be adapted to our business?
Yes. Themes, questions and levels can all be modified, and AI can generate a version tailored to your business, whether processing, trading, warehousing or distribution, based on your own procedures. Control of the framework remains yours.
How can several sites or business units be compared?
Each site is assessed against the same framework, making scores comparable theme by theme. The benchmark positions each entity relative to the others and to its own past assessments, and a cross-site roadmap consolidates shared actions.
Does the assessment cover withdrawal, recall and RASFF alert obligations?
Yes for Articles 19 and 20: trigger criteria, consumer recall decision, notification of the competent authority and internal alert chain. Obligations specific to the rapid alert network are covered by a dedicated framework, reusable within a shared roadmap.
Where is the data hosted?
In France, with OVH, with backup at Scaleway. No transfer outside the European Union. The AI models used can be selected, including from European solutions.