Producers are responsible for ensuring the quality, safety and regulatory compliance of their products. In order to fulfil this role appropriately and effectively, producers must have the ability to trace their products in order to react quickly and effectively should any consumer safety issue arise.

Producers often use an identification number or mark – otherwise known as a lot code – as part of their traceability strategy, in order to quickly and efficiently identify the lot (ie, batch of sales units of a foodstuff produced, manufactured or packaged under practically the same conditions) from which a product was part. Lot codes will typically include information such as the line of production, batch number and the bottle reference. The production date can also be part of the lot code, either in a detailed (e.g. 2023.02.03) or in a coded fashion, depending on the operator. All these elements will allow producers to conduct a swift and thorough recall of affected products should any issues arise. Lot codes are also used by operators for protection against counterfeiting, considering that they are unique to a given product.

Australia and New Zealand

Legislative framework

In both Australia and New Zealand, the Food Standards Code mandates that food for sale must bear a lot identification.

Moreover, there is a prohibition on defacement: “A person who sells a food for sale that is packaged, or deals with a packaged food for sale before its sale, must not deface the label on the package unless:

(a) the relevant authority has given its permission; and

(b) if the relevant authority has imposed any conditions on its permission—those conditions have been complied with.”

There is a specific provision to permit instances where there would be a need to re-label or oversticker in order to be compliant with the Code.

Penalties in case of infringement of the rules

Australia: According to the Food Act 1984, “a person must not sell or advertise any food that is packaged or labelled in a manner that contravenes a provision of the Food Standards Code. Penalty: AUD$40 000 in the case of an individual and $200 000 in the case of a corporation”, and “a person must not sell or advertise for sale any food in a manner that contravenes a provision of the Food Standards Code. Penalty: $40 000 in the case of an individual and $200 000 in the case of a corporation”.

If you would like a toolkit for lot code and traceability requirements for export requirements, please contact Paul McLeay.