Food & Beverage FAQ
Frequently asked questions on food regulation, safety, traceability, certifications and food supply chain management.
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What does Article 18 of Regulation (EC) 178/2002 require for food traceability?
Article 18 requires all food and feed business operators (FBOs) to implement systems and procedures that allow identification of suppliers (one step back) and customers (one step forward). They must be able to provide this information to competent authorities on demand. This "one step back, one step forward" principle is mandatory across all EU food chain operators except primary producers (who have simplified rules).
What is the difference between Use-By Date and Best Before Date?
The Use-By Date applies to highly perishable microbiologically sensitive products (fresh milk, fresh meat, fish, fresh pasta). After this date the product is unsafe and cannot be legally sold. The Best Before Date (BBD) applies to products that may lose quality after the date but are not necessarily unsafe - they may still be sold and consumed at reduced quality. The distinction carries major implications for food waste reduction: BBD products can be donated or sold discounted after the date; use-by products cannot.
When is an HACCP plan mandatory?
HACCP is mandatory for all food business operators (FBOs) beyond primary production under Regulation (EC) 852/2004. Primary producers (farming, livestock, fishing) follow simplified hygiene rules (good hygiene practices). The HACCP plan must be documented, implemented, maintained and reviewed whenever there is any change to the process, products or ingredients.
What are the 14 allergens that must be declared in food labelling?
Under Annex II of EU Regulation 1169/2011: cereals containing gluten (wheat, rye, barley, oats, spelt, kamut), crustaceans, eggs, fish, peanuts, soybeans, milk, tree nuts (almonds, hazelnuts, walnuts, cashews, pecan nuts, Brazil nuts, pistachio nuts, macadamia nuts), celery, mustard, sesame seeds, sulphur dioxide and sulphites (>10 mg/kg or 10 mg/l), lupin and molluscs.
How is a food product recall managed operationally?
Key steps: (1) Identify and confirm the safety issue; (2) Activate the crisis team; (3) Trace all affected lots using the traceability system; (4) Block remaining stock in warehouse; (5) Notify competent authorities within 24h (mandatory under Art. 19 Reg. 178/2002); (6) Contact all direct customers with hold/return instructions; (7) Issue consumer communication if product has reached retail; (8) Recover and manage disposed product with documentation; (9) Close recall with effectiveness verification (target: ≥99% recovery); (10) Root cause analysis and corrective action.
What is the difference between PDO and PGI under EU quality schemes?
For PDO (Protected Designation of Origin), all stages of production, processing and preparation must take place in the defined geographical area. For PGI (Protected Geographical Indication), it is sufficient that at least one stage of production, processing or preparation occurs in the geographical area. PDO has a stronger and more exclusive territorial link.
How does supplier qualification work under BRC/IFS requirements?
BRC and IFS require a formal risk-based supplier approval process including: (1) risk assessment of the raw material/service; (2) collection and verification of documentation (certifications, specifications, CoA history); (3) on-site audit for high-risk suppliers (or remote audit); (4) laboratory analysis of samples; (5) formal approval decision; (6) insertion in the Approved Supplier Register; (7) ongoing monitoring with periodic reassessment, non-conformity tracking and performance review.
What is the key difference between BRC and IFS food safety standards?
Both are GFSI-benchmarked food safety standards with similar scope, but differ in origin and market focus: BRC (British Retail Consortium) is prevalent in UK and Anglo-Saxon markets; IFS (International Featured Standards) is prevalent in continental Europe (France, Germany). Scoring systems differ: BRC uses a grading system (AA, A, B, C, D); IFS uses a percentage score (≥98.5% = Higher Level, ≥75% = Foundation Level). Many companies export-oriented toward all of Europe obtain dual certification.
What is the "one step back, one step forward" traceability principle?
This is the core traceability principle of Regulation (EC) 178/2002, Article 18: each food operator must know who supplied them their raw materials (one step back) and who received their products (one step forward). The regulation does not require full farm-to-fork traceability by a single operator - each link in the chain is responsible for its step. Together, however, the links form a continuous traceable chain enabling full reconstruction in case of a safety incident.
When must a food establishment be approved rather than just registered?
Simple registration (with the local health authority) is sufficient for most food businesses. Formal approval (assigned a health mark/oval EU approval number) is required under Regulation (EC) 853/2004 for establishments handling products of animal origin intended for intra-EU trade: slaughterhouses, cutting plants, dairy establishments, egg product establishments, fisheries establishments and facilities producing composite products. Approved establishments are listed in the EU TRACES database.
What documents must accompany a food shipment?
Key documents include: delivery note (transport document confirming lot numbers, quantities, product details), Certificate of Analysis (CoA) for certain categories, transport temperature records (for cold chain products), phytosanitary or veterinary certificates for imports, organic transaction certificate (for certified organic products), customs declaration (for imports from third countries).
How do allergen cross-contact risks need to be communicated on labels?
If after implementing all technically feasible control measures (production scheduling, physical separation, validated cleaning procedures) there remains a residual risk of cross-contact with a major allergen, the product must carry a precautionary allergen labelling (PAL) statement such as "may contain [allergen]." PAL decisions should be based on a formal risk assessment (using tools like VITAL 3.0 reference doses). "May contain" must not be used as a default substitute for proper allergen management.
What is RASFF and how does it operate?
RASFF (Rapid Alert System for Food and Feed) is the EU network enabling fast information exchange between national food safety authorities (31 countries), the European Commission and EFSA when a food risk is identified. Four notification types: Alert (serious immediate risk), Information (less serious or product not yet on market), Border Rejection (product refused at EU entry point), News (other relevant information). Notifications are publicly available on the RASFF portal.
What is the purpose of a HACCP mock exercise?
A mock HACCP or recall exercise tests the practical effectiveness of the traceability system and recall procedures without an actual food safety incident. BRC and IFS require at least one annual mock recall exercise. The exercise traces a randomly selected finished product lot back to its raw material lots and forward to all delivery destinations, verifying the completeness of records, the time required (<4 hours target) and the accuracy of the mass balance.
What is the difference between food safety, food quality and food fraud?
Food safety concerns protecting consumers from unintentional hazards (pathogens, chemical contaminants, physical hazards) that could cause harm. Food quality concerns the product's compliance with specification and consumer expectation (taste, texture, appearance) but does not directly affect safety. Food fraud (or economically motivated adulteration - EMA) is intentional deception for financial gain: adulteration, substitution, dilution, misdescription of origin. All three are addressed in modern food safety standards (HACCP for safety, specifications for quality, VACCP for fraud).
How are maximum limits for mycotoxins regulated in the EU?
Regulation (EC) 1881/2006 (as amended) sets maximum levels for mycotoxins in foodstuffs. Key limits: aflatoxin B1 in cereals: 2 µg/kg (max 5 µg/kg for maize intended for further processing); aflatoxin total (B1+B2+G1+G2): 4 µg/kg; aflatoxin M1 in milk: 0.05 µg/kg; ochratoxin A in cereals: 3–10 µg/kg; deoxynivalenol (DON) in cereals: 750–1750 µg/kg; zearalenone in cereals: 50–100 µg/kg; fumonisins B1+B2 in maize: 1000–4000 µg/kg; patulin in apple juice: 50 µg/kg.