PRODUCT TRACEABILITY REGULATIONS: WHAT SHOULD RETAIL AND FOOD ENTERPRISES PREPARE?

In light of regulatory authorities strictly enforcing market transparency and consumer rights protection, product traceability regulations have become a mandatory and pivotal legal requirement for enterprises, particularly those operating in the retail and food processing sectors.

Pursuant to the Law on Product and Goods Quality 2007, the Law on Food Safety 2010, and guiding legal instruments such as Decree No. 37/2026/ND-CP and Circular No. 02/2024/TT-BKHCN on product traceability management, proactively preparing technical and legal infrastructure not only ensures regulatory compliance but also establishes a core competitive advantage.

1. What Do the New Regulations Require?

Under national technical standards on product traceability, enterprises manufacturing, processing, and distributing goods (especially agricultural produce, packaged food, and pharmaceuticals) are required to adhere to the principle: “One step back – One step forward”.

Specifically, businesses must accurately identify from which supplier a batch was received (one step back) and to which distributors or retailers that batch was sold (one step forward). Minimum mandatory records include: product name, images, product/batch identification codes, manufacturer details, production/processing logs, and quality inspection documents.

2. Technical Requirements for Traceability Systems

• Barcodes & Traceability Labels: Goods in circulation must carry standardized traceability codes (such as QR codes compliant with TCVN national standards) linked to the National Product Traceability Portal.

• Real-time Data Retention: Supply chain data must be retained for a minimum of 12 to 24 months (depending on shelf life) and be readily retrievable during regulatory inspections.

• Data Immutability: Production logs and delivery records must maintain data integrity to prevent falsification of origin documentation.

3. Actionable Checklist for Retail and Food Enterprises

• Audit and Standardize the Supply Chain: Review all incoming supplier contracts. Exclusively partner with suppliers offering complete traceability documentation and food safety certifications (HACCP, ISO 22000, VietGAP, GlobalGAP, etc.).

• Invest in Digitalization: Implement Warehouse Management Systems (WMS), POS systems integrated with QR traceability scanning, and electronic logging software to replace manual record-keeping.

• Establish Product Recall Procedures: Pursuant to Article 55 of the Law on Food Safety 2010, enterprises must draft emergency traceability protocols to rapidly isolate and recall non-compliant or unsafe product batches.

• Staff Training: Conduct training for procurement, warehouse, and retail personnel on verifying valid traceability labels before goods are displayed on shelves.