Updated on 6 October 2026 · Reviewed by the FiscalControl technical team, HACCP consultants in the Algarve.

Direct answer: Yes. Food traceability is a legal duty. Article 18 of Regulation (EC) No 178/2002 requires food business operators to identify who supplied a product and to whom they supplied it next — the “one step back, one step forward” principle. In practice, for any ingredient or dish, you should be able to establish its supplier, batch, date of receipt, storage conditions and use within minutes. If you cannot do that for a product in your kitchen today, your traceability system has a real gap.

Try the five-minute test now

Pick a random product in your kitchen — a bag of frozen prawns, a container of olive oil or a cheese. Without searching for more than five minutes, answer four questions: who supplied it, what is its batch number, when was it received, and where is its invoice or delivery note? This simple test quickly shows whether your restaurant can trace its food.

If you can answer all four questions promptly, your system is working. If you have to search several places or cannot find the answers, an ASAE inspection or a product recall will expose that gap.

What the law requires: “one step back, one step forward”

Article 18 of Regulation (EC) No 178/2002, the EU General Food Law, requires traceability at all stages of food production, processing and distribution. Every operator must be able to identify at least the business that supplied a product and the business to which it was supplied.

For a restaurant, the crucial task is knowing the supplier of every ingredient entering the kitchen. The next step is usually the customer who consumes the dish, so the most important part of the chain for many restaurants is the step back to the supplier.

The six stages of food traceability

To reconstruct the journey of a product in minutes, document each stage:

Receipt: the date and time the product arrived.
Supplier: clear identification of the supplier, supported by an invoice or delivery note.
Batch: the product batch number, where applicable. Record it for prepacked goods and for fresh products whenever the supplier provides it.
Storage: where and under what conditions the product was kept before use.
Use: which dishes or preparations contained the product and on which dates.
Withdrawal: if a product must be withdrawn, the ability to identify affected dishes or customers quickly.

Most establishments keep invoices, so the first two stages are reasonably organised. The common weakness lies in linking a specific batch to the specific dish in which it was used, making an effective withdrawal much harder.

Documents that support each stage

Traceability does not require a complex system. Existing invoices and delivery notes need to be organised so they can be searched, while a simple record should connect higher-risk ingredients to the dishes in which they were used, particularly fish, seafood, meat and dairy products.

An internal traceability record can be a daily sheet listing the product, supplier, batch where applicable, date of receipt and preparations in which it was used that day.

What to do when there is a product alert or recall

Article 19 of Regulation (EC) No 178/2002 requires an operator to inform the competent authority immediately when there is reason to believe food placed on the market is unsafe, and to withdraw or recall it as appropriate. If a supplier issues a recall alert for seafood, eggs, dairy or another product, you need to establish quickly whether you received the affected batch and where it was used. That speed directly affects your ability to protect customers.

The Listeria monocytogenes rules in force since 1 July 2026 make this connection between batch and dish particularly important when a positive result requires prompt action.

Common traceability mistakes in restaurants

Keeping invoices without organising them by product or date, so they are hard to find when needed.
Failing to record a batch number for fresh products even when the supplier supplies it.
Recording the purchase of fish but not which dishes used that particular batch or when it was served.
Relying on staff memory instead of written records, especially in kitchens with frequent staff changes.

In summary

Food traceability is the practical ability to answer “where did this product come from and where was it used?” within minutes. Article 18 of Regulation (EC) No 178/2002 requires operators to identify the immediate supplier of a product. Organised invoices, recorded batches and a daily usage log make the difference between a prompt response and a poorly managed inspection or recall.

Frequently asked questions

Must I record the batch number of every product I buy?

For prepacked products, the supplier generally provides a batch number; record it whenever available. For fresh products without a formal batch number, you should at least be able to identify the supplier and the date of receipt.

How long should traceability records be kept?

There is no single legal retention period for every case. Recommended practice is to retain records at least for the product’s shelf life plus a reasonable period in which a consumer might report a problem. Many HACCP plans use a minimum of six months to one year.

What should I do if a supplier sends a recall alert?

Check immediately whether you received the affected batch, stop using any remaining product, and identify whether and when it was served. Where required, inform ASAE under Article 19 of Regulation (EC) No 178/2002.

Does traceability apply only to foods of animal origin?

No. The “one step back, one step forward” principle applies to all foods, although higher-risk products such as meat, fish, seafood, eggs and dairy usually warrant more detailed controls.

Test your traceability before ASAE does

If you could not pass the quick test at the start of this article, review your system now, before an inspection or recall tests it for you.

⚠️ Being unable to reconstruct the origin of a product in minutes is a serious weakness during an ASAE inspection.

With FiscalControl, you get:

✅ An audit of your current traceability system.
✅ Simple record templates adapted to your operation.
✅ A clear link between suppliers, batches and dishes served.
✅ Direct support during an inspection or recall alert.

👉 Request a free quote within 24 hours

No commitment. No small print. Just peace of mind.

We support restaurants and hotels throughout Portugal, with a strong presence in the Algarve — Faro, Portimão, Albufeira, Lagos, Loulé, Tavira and Vilamoura.
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