Food Traceability Implementation Guidance for Growers
This article is intended for Growers who are NOT packing the product (i.e., their only role is that of a primary producer).
How to identify the farm?
Growers need to use the Business Identification (BID) to identify the farms they manage (also called Farm ID). The BID can be used to uniquely identify a single Farm and its premises. The BID is allocated by the Ministry of Agriculture or any other designated government agency which maintains the National Farm Registry.
What additional farm information is required?
It is recommended to the Growers to identify all the plots in every farm they manage and if possible, all the crops in every plot. This shall give the opportunity to identify all the agricultural inputs used in every plot and crop.
If all the crops are mixed in one plot (thus impossible to differentiate them), then it is assumed that all inputs used for one crop are used for all the other crops in the same plot. In the same sense, if it is not possible to differentiate the plots in a Farm, then it is assumed that all the inputs used for one plot are used in the whole Farm.
Capturing production inputs:
To enable traceability, growers must maintain records of essential information related to the production of the product (e.g., agricultural inputs used, including date of application).
Information that must be recorded when buying or receiving, and retained:
Each time a grower buys or receives a product that may be applied to the crop it is required to retain a copy of the Sales Receipt given by the supplier. The Sales Receipt copy should at least include the following information:
- Supplier/Seller name
- Supplier/Seller contact information
- Supplier BID
- Customer name
- Customer BID
- Product Description (Brand name if applicable, including variety)
- Lot number or other batch identifier of the good
- Quantity and packaging information
- Purchasing or receiving date
- Address from where the good was purchased/delivered
- Name and contact information of the transporter
- Any other information deemed appropriate by the Competent Authority
It is recommended for growers to also include the following information:
- Sales Receipt number
- Product identification number (if available)
- Name and signature of person who received the product
- Name and signature of person who dispatched the product
It is important to highlight that it is the Grower´s decision to record this information also in a registry.
Identification of trade items and grower information:
Each Trade Item destined for a subsequent trading partner (i.e., packing facility, retailer facility) must be identified. Examples of Trade Items include bags, cartons, bins, totes, containers, trailers (normally the container the Grower uses to transport the product).
To assist customers with their subsequent traceability, growers shall attach a tag/label to their Trade Items, in human-readable format (could be handwritten), with all relevant grower/harvest information. Products are labelled at the time of packaging or distribution.
Identification of batches/lots:
Growers must assign a batch/lot number to the products they harvest. The batch /lot number itself depends on the grower’s criteria. For example, a batch/lot number can represent a harvesting day and for a specific crop or may be the harvesting date for the entire farm. The batch/lot should be internally linked to the Farm/crop information and records.
Minimum information that must appear on the Trade Item label:
Each Trade Item shall provide at least the following data in human-readable format:
- Grower´s name
- BID (Farm BID)
- Commodity name and, where applicable, variety name
- Lot number (use of the harvesting date is recommended)
- Code for date marking, as required by relevant legislation
- Quantity
Traceability information to be recorded:
Growers shall record (on paper or in electronic form) the required information associated with each plot/crop in any farm (BID) that they manage. These records should be organized chronologically by dates.
To record the traceability information, the use of a “Farm Book” is recommended. The “Farm Book” is a simple notebook (e.g. a copybook) wherein a grower records cultural practices, plant protection treatments and additional information that may be considered of importance in relation to crop management. This tool gives the growers control over their farm, providing a method to record chronological information about the production of any crop within a harvesting season.
Information that must be recorded when using agricultural inputs:
Each time a grower applies or uses a product (agricultural input) in a plot or crop, the following information is recorded.
- Farm Name
- Farm BID
- Plot identification (and crop identification if possible)
- Date of application
- Product Description (Brand name if applicable, including variety)
- Lot number or other batch identifier of the good
- Supplier BID
- Quantity applied
Information that must be recorded and retained when selling:
Each time a grower sells a Trade Item to a trading partner, the following data must be recorded in order to ensure that the traceability link is maintained. These represent the minimum data set required to ensure traceability between the grower and their trading partners.
- Supplier/Seller name
- Supplier/Seller contact information
- Supplier BID
- Customer name
- Customer BID
- Product Description (Brand name if applicable, including variety)
- Lot number or other batch identifier of the good (i.e. harvesting date)
- Quantity and packaging information
- Date of transaction
- Origin Address: Address from where the good was delivered
- Destination Address: Address of receiving location/trading partner
- Name and contact information of the transporter
- Any other information deemed appropriate by the Competent Authority
This information is recorded in a sales receipt or any other documentation involving the sale or transfer of a trade item.
It is recommended that growers also include the following information:
- Sales Receipt number
- Product identification number (if available)
- Price
- Name and signature of person who dispatched the product
- Name and signature of person who received the product
It is important to highlight that the Grower needs to record the same information as the one that appears in the Sales Receipt. Thus, the decision to record this information in a registry such as the Farm Book is up to the Grower.
If the Grower does not have the means to provide a “Sales Receipt” to his/her customers, s/he can ask the customer to provide the “Sales Receipt” when receiving the products and then keep a copy of the Sales Receipt. In any case, both the Grower and the customer must retain a copy of the Sales Receipt. This requirement only applies when the customer is a Trading Partner (i.e. retailer, packer, exporter, distributor, hotel, and restaurant).
Data retention:
All companies are expected to maintain / retain records that will facilitate timely and accurate traceability and support any product recalls.
Records are retained at a registered location or at another readily available location and made available to the Competent Authority within the time limit prescribed by [rule/order] approved by the Competent Authority. In the absence of a prescribed time, the retention time should be the maximum time by which the produce is consumed plus a safety margin of six months.
Recall and withdrawal:
Since the growers do not have the resources to recall/withdraw, it is suggested that the responsibility for recall/withdrawal upstream be placed on the packers and re-packers. As mentioned in the previous section, they only need to have the records on site or at a readily available location in order to be retrieved “as soon as possible” after request by any partner or by the competent authorities on demand.
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