Food and agricultural traceability

Traceability is not a stand-alone chapter of any food quality system: it is the requirement that runs through all of them. ISO 22000, IFS, BRC and GlobalG.A.P. each demand, in their own language, the same underlying capability: the ability to trace a batch backward (which raw material, from which supplier, with what treatments) and forward (which client received each batch made with that origin). The legal basis for that requirement, across the whole European Union, is Article 18 of Regulation (EC) No 178/2002, Article 18: it requires the traceability of food, feed and food-producing animals to be ensured at all stages of production, processing and distribution, and requires every operator to be able to identify both who supplied them and whom they supplied.

The first link in that chain, for any farm, is the record of what happens in the field: which plot, which plant-protection treatment, on what date, with what pre-harvest interval. That record exists today in two possible formats, paper or digital farm record book (cuaderno digital de explotación), and it is worth being clear about the real situation, because all sorts of claims have circulated about whether it is mandatory. Royal Decree 1054/2022 created the farm and livestock information system (SIEX), the regional register of farms, and the digital farm record book itself. Royal Decree 34/2025 amended that rule: the digital farm record book remains, in itself, voluntary to fill in unless another sector-specific rule requires a particular electronic record. And that sector-specific rule does exist for one very specific piece of data: the electronic record of plant-protection product treatments is imposed by Implementing Regulation (EU) 2023/564. For non-agricultural operators it was already mandatory, under Royal Decree 285/2021 itself; for agricultural holdings, Royal Decree 34/2025 allowed paper records to continue until 31 December 2025, and Royal Decree 1039/2025 extended that deadline by one more year, so paper remains valid until 31 December 2026 and the electronic record becomes mandatory for agricultural holdings from 1 January 2027.

That legal obligation, with its calendar and its nuances by type of holding, is handled by Summum Consultoría, which tracks it rule by rule because it changes with every royal decree. We focus on the other half of the problem, the half the legal obligation alone does not solve: making sure that field record connects with the rest of the quality system, so that a piece of data captured once serves the entire traceability chain instead of becoming an isolated document that nobody looks at again until an auditor asks for it. If the farm record book is being rolled out as part of a Kit Digital project, the grant application process is explained on this page.

The digital tool itself, connected to the CAP, SIGPAC and whichever sector-specific modules a given holding needs (PDO/PGI, a winery running SILICIE 2.0), is Campodato, from Summum Sistemas (also at campodato.es). This service is the one that connects that tool, or whichever record book the holding already uses, with the certifiable quality system: what gets recorded, where it gets recorded and who records it, so that same piece of data feeds the backward and forward traceability that ISO 22000, IFS/BRC or GlobalG.A.P. will ask for.

We also do something rarely done before an audit: we take a real batch and trace it from end to end, from the plot to the dispatch note, to find where the chain breaks while there is still time to fix it. That is the difference between a system that exists on paper and one that genuinely withstands a client's or an auditor's question about a specific batch.

What traceability records at each link of the chain

Food and agricultural traceability is not a single record, but a chain of records that have to be linkable to each other by batch. Each link holds a different type of data, and the most common failure is not a single missing data point, but two consecutive links not sharing the same batch reference, which breaks the link.

When a batch combines raw material from several origins, as is common in processing, the blend formula or "mass balance" is also needed: what proportion of each origin batch went into the final batch. Without that data, backward traceability stops exactly at the processing stage.

The legal basis: Article 18 of Regulation (EC) No 178/2002

The traceability requirement does not come from any ISO standard or client demand: it comes from Regulation (EC) No 178/2002, the framework regulation of European food law. Its Article 18 requires the traceability of food, feed and food-producing animals to be ensured "at all stages of production, processing and distribution", and requires every operator to have two specific capabilities: the ability to identify who supplied them (backward traceability) and the ability to identify whom they supplied (forward traceability), with that information available to the competent authorities on request. We cover in more detail what each operator must record in this article on product traceability requirements.

ISO 22000, IFS, BRC and GlobalG.A.P. do not invent a new requirement on top of this base: they spell it out and audit it with their own methodology, each adding its own nuances (response times for an alert, product withdrawal drills, the depth of record required according to risk). Getting the underlying legal requirement right is what turns each specific certification, afterwards, mostly into a question of format and documentary evidence, not rebuilding the system from scratch.

The digital farm record book: what is mandatory today and what is not

All sorts of claims have circulated about the digital farm record book, and it is worth separating what applies from what does not. Royal Decree 1054/2022 created the farm and livestock information system, the regional register of farms, and the digital farm record book itself (CUE). Royal Decree 34/2025 amended that rule in 2025: the digital farm record book itself remains voluntary to fill in as long as no sector-specific rule requires a particular electronic record.

That sector-specific rule does exist, and it is where there really is a deadline: the electronic record of plant-protection treatments is imposed by Implementing Regulation (EU) 2023/564. For non-agricultural operators it was already mandatory under Royal Decree 285/2021; for agricultural holdings, Royal Decree 34/2025 allowed paper records to continue until 31 December 2025, and Royal Decree 1039/2025 extended that entry into force by one more year: paper remains valid until 31 December 2026, and the electronic record is mandatory for agricultural holdings from 1 January 2027. The full calendar, with its nuances by type of holding and whatever regulatory news follows, is tracked by Summum Consultoría as its own service; here we work to make sure that record, whether voluntary or mandatory, is connected to the rest of the traceability system.