For any SME or OME who produces materials or articles which are supposed to contact to food, the FCMs supply chain is in need when they think about spreading their market share out of their circumscription in other nations.
Article 17 of the framework regulation states that business operators must have in place systems and procedures to allow identification of the business from which and to which materials or articles are supplied and that the materials and articles must be identifiable to allow their traceability by labeling or via relevant documentation.
The ‘Industrial guidelines on traceability of materials and articles for food contact’ (2006) define two levels of traceability, as follows.
The industrial guidelines give a simplified structure of the organisation of the FCM supply chain, as is illustrated in the following figure.
Figure 1: Simplified structure of the organisation of the FCMs supply chain
The guideline states that ‘using the above diagram, it is possible to identify a point where the FCM or article is manufactured, i.e. the converters and producers. At this point, there is a separate identity, “upstream” and “downstream”. Converters transform materials, which have been produced by “upstream” suppliers, into finished articles or semi-finished goods. Producers manufacture articles directly from starting materials, using processes involving chemical, as well as physical change.’
The scheme illustrated above assumes that the whole chain is within the EU. However, in some cases, part of the chain can be outside the EU; therefore another stakeholder should be included in the scheme, namely the importer. Imports may take place at different stages of the supply chain, such as:
In an ideal supply chain, e.g. a chain composed entirely of ISO 9000 certified companies, traceability will always be guaranteed, as every single step of the chain will have been documented. In practice, different identification rules may apply for upstream and downstream users. Upstream suppliers supplying a company operating under a certified quality system shall strictly guarantee the traceability of their products. It is essential that companies operating under a certified quality system control their suppliers and ensure that the supplied products are appropriately identified.
Figure 2 is an attempt to visualise the supply chain across the various materials. Since importers can act in the whole supply chain, they have been omitted from the figure (above).
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