One-up, one-down traceability:
what the law requires, and what it quietly doesn't.
Every food business in the EU is legally required to know where its inputs came from and where its outputs went, one step up, one step down. That sentence hides two traps: the law does not require internal traceability, and one-up-one-down alone will not survive a retailer audit. Here is the full picture, with a worked example.
What Article 18 of EU food safety regulations says
Article 18 of Regulation (EC) No food safety, the General Food Law, requires food business operators to be able to identify any person from whom they have been supplied with a food, a food-producing animal, or any substance intended to be incorporated into a food (one step back), and to identify the businesses to which their products have been supplied (one step forward). This information must be available to the competent authorities on demand.
Article 19 adds the operational teeth: if you have reason to believe food you placed on the market is not safe, you must immediately withdraw it, inform the competent authorities, and, where product may have reached consumers, effectively and accurately inform them and recall it if necessary. In Ireland the competent authority framework runs through the FSAI and its official agencies.
Notice what Article 18 does not require: it does not mandate internal traceability (linking a specific incoming lot to a specific outgoing batch inside your factory), it does not mandate lot-level granularity, and it does not set a time limit. Those obligations arrive from elsewhere, certification standards and customer contracts.
A worked example: one wheel of blue cheese
Take a farmhouse dairy making blue cheese. Tuesday's milk arrives from three farms and is pooled into one silo. Wednesday's make-day consumes that silo into batch B-1042, 214 wheels. Over the following weeks, wheels from B-1042 are dispatched to an Irish multiple (under a private-label code), a UK distributor, and a Dublin cheesemonger.
| Question | One-up-one-down answer | What an incident actually needs |
|---|---|---|
| A farm reports a residue failure in Tuesday's milk | We received milk from farms X, Y, Z on Tuesday | Which batches used Tuesday's milk, which wheels, which customers received them, how many are still in stock |
| The multiple queries a private-label SKU | We supplied that customer on those dates | Which internal batch that SKU line resolves to, its full QC record, its milk origin |
| The FSAI asks who received batch B-1042 | List of direct customers | Same, plus quantities per customer and dates, ideally within hours |
The left column is legal compliance. The right column is what your customers, your certifier and, in a real incident, your own survival require. The gap between the two columns is internal traceability: the documented links between intake, silo, batch and dispatch that Article 18 never mentions.
What BRCGS, retailers and export markets add on top
The minimum record set that satisfies both law and audit
From legal minimum to operational capability
One-up-one-down is a floor, not a system. The producers who suffer in incidents are rarely missing the legal records, they are missing the connections between them, so answering "which customers got Tuesday's milk" means a person manually walking intake books, make sheets and dispatch folders under pressure.
This is the specific problem Keystone models: every supplier delivery, silo run, batch and dispatch line is one connected chain, so the incident question, either direction, is answered in under 30 seconds with a signed PDF for the authority or customer. The legal one-up-one-down evidence falls out of the same records automatically.
- Article 18 of EU Reg food safety requires one step back and one step forward, available to authorities on demand.
- The law does not require internal traceability or lot-level granularity; BRCGS and retailer standards do.
- Article 19 imposes immediate withdrawal, authority notification and consumer-level recall duties when food is unsafe.
- The gap that hurts producers in incidents is the missing internal links between legally-kept records.
- Keep traceability records for at least 5 years unless a stricter customer or sector rule applies.
Frequently asked questions
What does one-up, one-down traceability mean?
Does EU law require internal traceability?
Do I need to trace sales to consumers?
How long must food traceability records be kept?
What happens if I cannot trace a product during an incident?
See this done in software, on real production data.
Keystone runs the full chain, supplier delivery → batch → dispatch → customer, in under 30 seconds. 20-minute discovery call, no sales pitch.