Traceability obligations have been moving in one direction in recent years: identity at unit level, a recorded chain and machine-readable documentation. The timeline differs from industry to industry, but the direction does not.
Most organisations start preparing when an announcement arrives. The problem is that part of the data an obligation calls for cannot be produced retrospectively: which batch was made from which raw material cannot be found later if it was not recorded at the time.
Documents can be produced later; data cannot.
Data you can collect from today
- Unit identity: a unique number for every product. This is the most expensive layer to add afterwards.
- The batch link: already in your production records; what is missing is the link to the number.
- Supplier documentation: the certificate of analysis and the certificate of origin, matched to the batch.
- Location and custody: the points the product passed through and whose hands it was in.
All four can be collected today and none of them waits for an obligation. Once collected, they serve the business itself: recalls narrow, supplier disputes get shorter, and a question asked at export does not go unanswered.
The real measure of readiness
There is a practical way to tell whether an organisation is ready: pick a batch from last month and see how many minutes it takes you to find out which raw material it was made from, on which line, on which date, and where it went. If the answer is measured in minutes, you are ready; if it is measured in days, you are not.
Why the timeline starts early
The date an obligation takes effect is not the date preparation should start. Collecting data, asking suppliers for information and setting up the system take months; preparation that starts on the date of entry into force will be incomplete at the first inspection.
The second reason to start early is obligations that ask for historical data. Information not recorded today cannot be produced retrospectively two years from now.
Where preparation starts
The most productive starting point is an inventory of existing records: which information is already kept, where it is kept and how reliable it is. In most facilities what is missing is not the information itself, but having it in one place and up to date.
Preparation that starts on the date of entry into force will be incomplete at the first inspection.
