What to consider when selecting a lot code to meet traceability requirements under the Safe Food for Canadians Regulations
On this page
- 1.0 Introduction
- 2.0 Purpose
- 3.0 Definitions
- 4.0 Selecting a lot code
- 5.0 Lot code labelling
- 6.0 Additional information
The Safe Food for Canadians Regulations (SFCR) have been in force since January 15, 2019, and many food businesses, including those who sell food to consumers at retail, must meet the traceability requirements in Part 5 of the regulations. In order to comply with traceability requirements, you must be able to track the movement of the food you provide in the supply chain – forward to the immediate customer and back to the immediate supplier, as applicable.
If traceability requirements apply to your food business and the food you provide is a consumer prepackaged food that is not packaged at retail, you must ensure that a lot code is applied, attached or accompanies the food when you provide it to another person [SFCR, 92(2)]. It is important to note that there are exceptions to this requirement. Refer to Regulatory requirements: Traceability to find out if a food requires a lot code.
A lot code is one of the key components of assuring an effective traceability system. It can be used to identify and track food as it moves through the supply chain; for example, during manufacturing, distribution, sale at retail, and even after the product has been sold.
For example, when a potential food safety incident triggers a food safety investigation, lot codes can be used to help trace the food back to where it originated in an effort to pinpoint where the problem occurred. Lot codes can also be used to trace foods forward through the food distribution system to determine how far a potentially harmful product has been distributed.
Further, if the results of a food safety investigation indicate that a recall is necessary, a lot code can help to rapidly identify affected foods and remove them from the marketplace. By facilitating the quick and efficient removal of affected foods from store shelves and consumers' homes, lot codes can help to prevent or mitigate foodborne illness outbreaks and other threats to public health caused by contaminated, adulterated or improperly labelled foods.
While traceability requirements apply to most food businesses, they do not apply to restaurants and other similar enterprises. To find out if your food business must meet the requirements related to traceability, refer to the Traceability interactive tool.
Additional guidance on traceability can be found at Traceability for food.
The purpose of this document is to provide food businesses with information on:
- selecting an appropriate lot code
- lot code labelling requirements
Label: As defined in the Safe Food for Canadians Act (SFCA), a label includes a legend, word or mark that is or is to be applied or attached to or included in, or that accompanies or is to accompany, a food commodity or a package [SFCA, Section 2].
Lot code: The SFCR glossary defines lot code as a code that can be used to identify a lot that was manufactured, prepared, produced, stored, graded, packaged or labelled, under the same conditions. A lot code can be numeric, alphabetic or alphanumeric.
4.0 Steps to consider when selecting a lot code
When you are determining the conditions that you will use to define a lot, it is important for you to consider that the broader the scope of a lot, the broader the scope of a food safety investigation or recall may be, if one were to occur.
Step 1: Determine the lot
Before selecting a lot code, it is important to first determine the conditions that you will use to define a lot. All of the food in a lot must be either manufactured, prepared, produced, stored, graded, packaged or labelled, under the same conditions. This means that all of the food in the lot you define is identical in the relevant aspects of a specific manufacturing, preparation, production, storage, grading, packaging, or labelling practice or any combination of those.
Although food recalls are necessary to protect public health, they can have adverse impacts on the food businesses implicated, such as disruption of business and economic losses. Therefore, choosing more specific conditions to define a lot may not only benefit public health by contributing to a more rapid and efficient recall of affected food, it may also lessen the adverse impacts of a recall on food businesses by quickly removing the affected product and excluding product not implicated in the event.
You package strawberries into clam shell containers and label them in the field.
Scenario 1: You use broad conditions to define a lot.
You choose to define a lot broadly by selecting the growing region of the strawberries. In this case, if a recall were to occur, all of the strawberries grown in that region may be impacted.
Scenario 2: You use more specific conditions to define a lot.
You choose to define a lot using the harvest date of the strawberries. In this case, if a recall were to occur, the scope of the recall may be limited to fruit harvested on a specific date(s). This may contribute to a more rapid removal of the affected food from the marketplace and may also limit the economic impact of the recall on the food businesses involved.
Consider the following examples for determining the lot
A food business runs 1 production shift a day where it manufactures, prepares, packages and labels a food product.
- The food business decides that the "same conditions" would have presented themselves on that day
This food business determines that a lot represents:
- a day's production
A food business runs 2 production shifts a day where it manufactures, prepares, packages and labels a food product.
- The food business decides that the "same conditions" would have presented themselves on that day depending on the shift during which the food was made.
This food business determines that a lot represents:
- the day, and
- the shift during which the food was made
A food business runs 2 production shifts a day where it manufactures, prepares, packages and labels a food product on 2 production lines.
- The food business decides that the "same conditions" would have presented themselves on that day, depending on the shift and the line on which the food was made.
This food business determines that a lot represents:
- the day,
- the shift, and
- the line on which the food was made
Step 2: Determine the code
The "code" component of a lot code can be numeric, alphabetic or alphanumeric.
Keeping the 3 examples above in mind, the food businesses will now need to select a code that represents the same conditions they have chosen to define each lot.
Food businesses have the flexibility to choose how they want to capture this information. For each of the 3 examples, the "Code determination" column in Table 1 contains only 1 example of how the food businesses could code the information for each lot.
|Example||"Same conditions"||Lot information||Code determination||Lot code|
|Example 1||Production day||
||Since this food business applies a durable life date (also known as a "best before date") to their product, they may determine that this date will be dually used as a lot code provided it indicates the day the food was made.||Best before/ Meilleur avant: year-month-day|
|Example 2||Production day and shift||
The food business may decide on a code that represents the production date along with the applicable shift information. This may look something like:
|Example 3||Production day, shift and line||
Much like example 2, the food business may decide to add a line number to the code:
|Lot #: YYYYMMDDs#l#|
The examples provided in Table 1 show how a lot code can take on many forms, some of which may not be easily distinguishable. Although the SFCR does not require you to include terms such as "Lot #" before the lot code, doing so may help others identify this information when it appears on a label.
Food businesses should always be able to define their lot codes. In the case of a food safety investigation, recall, or in response to other regulatory verification activities, you should be able to clearly explain what your lot code means. This will ensure the correct product is scoped into an investigation or recall and will demonstrate compliance to the lot code requirement itself.
If you are not certain you have selected an acceptable lot code, ask yourself the following question:
"Does the code selected identify a lot that was manufactured, prepared, produced, stored, graded, packaged or labelled under the same conditions?"
If your answer is "yes", you have most likely selected a compliant lot code.
In the event of a food safety investigation or recall, a more specific lot code can assist in determining the cause of the food safety incident; it can also identify food not implicated with the incident.
If you would like to select a more specific lot code, a question to consider is:
"Have I selected a lot code that, in the case of a food safety investigation or recall, has the potential to limit the impact of the recall by excluding food not implicated in the incident?"
If your answer is "yes", you have most likely selected a lot code that could reduce the potential impact of food being recalled, if a recall were to occur.
5.0 Lot code labelling requirements
5.1 Traceability "apply, attach or accompany" – SFCR 92
Section 92 of the SFCR provides the labelling provisions related specifically to traceability. If the food you provide is required to have a lot code, it must be applied, attached or accompany the food when you provide it to another person.
Also, if you provide a consumer prepackaged food to another person, regardless of whether you were the food business who prepared it, you are required to ensure the label that is applied, attached or accompanies the food has a lot code [SFCR, 92(2)].
It is important to note that if you decide to use another core labelling requirement as a lot code, the core labelling component itself may have to meet specific requirements related to how it is applied, attached or how it accompanies the food. In most cases, for prepackaged foods, this will mean that the label must be applied or attached and the option to accompany the food will no longer apply [SFCR, 214, 217]. For example:
- if you apply a durable life date and decide to use it dually as a lot code, the requirement that the lot code must be "applied, attached or accompany the food" is now prescribed by the durable life date requirements for that food
- if you grow or harvest fresh fruits or vegetables and choose to use the growing region (part of the principle place of business) dually as a lot code, the requirement that the lot code must be "applied, attached or accompanies the food" is now prescribed by the name and principal place of business requirements for that food
For additional information, refer to the General section under the Food products that require a label page in the Industry Labelling Tool.
5.2 Traceability "ensure" – SFCR 92(1)
As noted in SFCR 92(1), any person referred to in subsections 90(1) and (2) must ensure a consumer prepackaged food, that was not packaged at retail, has a label that includes a lot code when they provide this food to another person.
If you are not the food business who manufactured, prepared, produced, stored, graded, packaged or labelled the food under the same conditions, for example a distributer or retailer, the consumer prepackaged food should already have a lot code when it is provided to you.
A retailer receives consumer prepackaged food from a Safe Food for Canadians (SFC) licence holder who manufactured, prepared, produced, stored, graded, packaged and labelled the food under the same conditions.
- The SFC licence holder is required to ensure the consumer prepackaged food they provide has a label with a lot code as they are a person listed in SFCR subsection 90(1)
- The retailer is also required to ensure the label of this consumer prepackaged food has a lot code when they provide this food to another person [SFCR, 90(2)]
- Since this consumer prepackaged food has already been labelled with a lot code by the SFC licence holder, the retailer is not required to create a different lot code
How the retailer ensures the food they provide is labelled with a lot code is up to them. For example, the retailer may establish criteria or requirements that their suppliers need to meet. These agreements can ensure compliance to the requirement for a lot code, but they do not absolve either party from their responsibility to comply with the SFCR. In this example, the agreement could set out the details of the lot code, what it means, and where it can be found on a label so that it is quick and easy to verify for compliance and during a recall.
Refer to the Supplier Food Safety Assurance Program to learn more about developing procedures that may help to ensure that the consumer prepackaged food you receive and provide meets lot code labelling requirements.
5.3 Official languages – SFCR 206
Section 206 of the SFCR requires that a lot code to be shown in both French and English if the food you provide is a consumer prepackaged food and your lot code
- contains one or more words, or
- includes one or more words as a prefix
There is, however, an exception for cases where the label is authorized to show information in only one official language under subsections B.01.012(2) to (10) of the Food and Drug Regulations (FDR).
5.4 Legibility – SFCR 208
Section 208 of the SFCR requires that all of the information that appears on a food label, including a lot code be:
- clearly and prominently shown, and
- readily discernible and legible to the purchaser or consumer under the customary conditions of purchase and use
The SFCR does not require a specific font size for a lot code on a food label. However, to meet the legibility requirements, a best practice could be for your lot code to be shown in characters that are at least 1.6 mm (1/16 inch) in height.
Often, the lot code of a consumer prepackaged food is ink jetted, stickered or stamped on the product's packaging. Therefore, if attached or applied to the label, the lot code can be either on the top, the bottom or the side of the packaging.
Examples of information on food labels that may not satisfy the above mentioned legibility requirements include:
- coloured text on a similarly coloured background, or
- impressed or embossed letters on cardboard or plastic where there is no prominence or contrast
5.5 Compliance to Part 11 (Labelling) – SFCR 203
As noted in section 203 of the SFCR, when any labelling information required by Part 11 of the SFCR is used dually as the lot code, for example a durable life date, all requirements that are prescribed in Part 11 for that particular labelling information apply to it. For example, the font size, location, format and bilingual requirements.
For more information refer to the Industry Labelling Tool and Regulatory requirements: Traceability.
6.0 Additional information
- Video: Traceability requirements under the Safe Food for Canadians Regulations
- Traceability interactive tool
- Regulatory requirements: Traceability
- Questions and Answers: Traceability
- Fact sheet: fresh fruits and vegetables businesses
- Food safety investigation and recall process
- Getting started: Toolkit for businesses
- Understanding the Safe Food for Canadians Regulations: A handbook for food businesses
- Date modified: