Traceability

Traceability in the food industry is defined as follows:

"the ability to follow the movement of a food through specified stage(s) of production, processing and distribution."

This is the definition adopted by the Codex Alimentarius Commission (an intergovernmental organization established by FAO and WHO to set international food standards) in 2004.Guide to Implementing a Food Traceability System” (2007nd edition, March 3. Prepared as part of a project subsidized by the Ministry of Agriculture, Forestry and Fisheries. hereinafter referred to as the "Guide") and also in ISO 2:22005, the ISO standard for food traceability.

Background of the growing interest in food traceability

Japan experienced failure to recall and identify the cause of major food poisoning incidents that occurred around 2000, resulting in market turmoil as consumers refrained from purchasing, and cases of false labeling of origin, etc. As a result, attention was focused on traceability as an effort to prepare for the occurrence of such incidents, along with measures to prevent the occurrence of such incidents (for example, the sophistication of food safety management).

The same was true in other countries. Around this time, the EU and the United States established and introduced regulations that require businesses to take minimum measures for traceability of all food products (creating and storing records of incoming and outgoing products, and providing information when required by government agencies).
As of January 2024, Japan has no regulations requiring the assurance of traceability for all foods. However, for cattle and beef (Beef Traceability Act), rice and rice products (Rice Traceability Act), and some marine products (sea cucumbers and abalone, which are subject to the Fisheries Distribution Optimization Act; see below), there are separate laws and requirements requiring businesses at each stage of the supply chain to ensure traceability.

Roles of each business operator and chain traceability

Food is delivered to consumers through multiple stages of business operators, including production (agriculture and fishing), processing, processing, wholesale, retail and restaurants. Traceability throughout the supply chain (chain traceability) cannot be achieved by the efforts of a single company alone. Business operators at each stage keep records to trace back one step upstream and one step downstream. Within the business, records are kept to show the correspondence between incoming goods (raw materials for processors) and outgoing goods (finished products for processors) (internal traceability) (Figure 1). When necessary, business operators at each stage provide these records to each other so that tracing and tracking can be performed. This is ensuring chain traceability (Figure 2).

Figure 1. Matching principles that each business operator must meet (principles 4 to 6)

Figure 2. Principles of matching and chain traceability that businesses at each stage must meet
Source: "Food Traceability System Implementation Guide", 2nd Edition, page 21

Approaches to ensuring chain traceability

So how can we make this happen?

The "Guide to Introducing a Food Traceability System" mentioned earlier states that "it is best to form an organization with multiple businesses and aim to introduce a traceability system throughout the food chain." In fact, there are cases where a group of businesses that handles specific items in a specific region, or a group of businesses that make up the supply chain for a specific brand product, have jointly worked on a traceability system.

In addition, large distribution companies may require their suppliers to implement traceability measures as a condition of doing business with them, and may also conduct retroactive tests during regular audits.
In addition, traceability efforts may be required as one of the standards for various certifications, including food safety.

However, if some business operators in the supply chain do not see the benefits worth the cost and do not record or provide information, traceability will be broken. If reliable traceability is required, a realistic approach would be to require all business operators at each stage to make minimum efforts by law and to allow government agencies to collect information and conduct investigations when necessary.

Purpose of seafood-specific traceability: Preventing distribution of seafood originating from IUU fishing

With regard to fishery products, traceability efforts have been promoted by businesses for the purpose of responding when food safety issues occur and verifying the accuracy of country of origin indication.Chain of Custody CertificationTraceability is one of the main requirements.

In addition, what is being promoted in Japan now isIUU (illegal, unreported, unregulated) fishingThis is to ensure traceability based on laws and regulations, with the aim of preventing the distribution of fishery products originating from these countries.Fisheries Distribution Optimization ActWith the adoption of the revised law, it has become mandatory for businesses at the processing and distribution stages, including retail and restaurants, to record and transmit the "catch number" assigned to shipped products by fishermen and fishing associations for abalone and sea cucumbers, which have often been illegally caught, from December 2022. Glass eels are scheduled to be added to the list from December 12. When suspicions arise, the competent authorities can clarify the presence and actual situation of illegal distribution by collecting and investigating records, including catch numbers, from businesses at each stage.

To ensure compliance with TAC and IQ

Total Allowable Catch (TAC),IQ (Individual Quota)In the EU and the US, where fishery resource management by the fishery management system is widespread, member countries/national fishermen are not only required to submit fishing logs and report landing volumes, but also oblige the first purchaser of the fishermen (the market receiver in case of shipment to a fishing port market) to provide electronic data of sales notes to the competent authorities, which indicate which fishermen (fishing vessels), when, which species, and how much they purchased. This makes it possible to check the TAC and IQ consumption status by using data from the purchasing business, rather than relying solely on the fishermen's self-declaration. Furthermore, the EU requires businesses in the supply chain, including retailers and restaurants, to ensure traceability of all fishery products by lot (specifically, lot identification, records of incoming and outgoing shipments, communication of catch information between businesses, and provision of information when requested by the competent authorities) (Article 1224 of EU Regulation 2009/58).

In Japan, full-scale TAC and IQ were introduced for bluefin tuna ahead of other fish species, and the effect of resource recovery is gradually being achieved. However, behind the scenes, illegal distribution is occurring, where fishermen sell their catch to middlemen without reporting it. Preventing this unreported distribution is essential for the success of full-scale resource management with TAC and IQ, not only for bluefin tuna. Ensuring traceability throughout the supply chain is expected to prevent the distribution of unreported catches, and to enable government agencies to investigate and crack down on them even if they are distributed. The use of digital technology is effective in reducing the burden of record-keeping, storage, and provision on businesses at each stage, such as processing and distribution, and future legal system design and information system design are important.

Global Move to Ensure Interoperability

With the EU, the US, and even Japan now requiring traceability information such as catch certificates based on their own legal systems, global companies, especially those exporting to markets in multiple countries/regions, are facing the challenge of ensuring interoperability of the traceability systems they and their suppliers have implemented. Specifically, it is expected that the mandatory items of information to be recorded at each stage and the format of data transmitted between businesses (i.e. between systems) will be standardized as much as possible. In 2011, ISO published standards for the information to be recorded at each stage (ISO 12875:2011, ISO 12877:2011).

In recent years, WWF and other organizations have called on global fisheries companies to establishGDST(Global Dialogue on Seafood Traceability)is working to develop a global standard for seafood traceability. In addition, the Seafood Alliance for Legality and Traceability (SALT), a program of the US NGO FishWise, has issued the Comprehensive Electronic Catch Documentation and Traceability (eCDT) Principles, a guideline for electronic catch documentation and traceability (eCDT), which electronically traces seafood catch, processing, and distribution processes. While the guidelines are primarily intended as recommendations for government initiatives, they can also be used by companies and NGOs to improve their own organizational initiatives.

Written by Jun Sakai, Secretary General of the Seafood Traceability Council