GLOBAL TRACKING/TRACEABILITY

INFORMATION EXERCISE

Template for a Global Practice

SUMMARY AND ACTION POINTS

1. During February 2014, the OECD Working Party on Consumer Product Safety

requested public input on the feasibility of specific practices aimed at improving tracking

information on consumer products.

2. In addition, some jurisdictions, among them the United States and the European

Union, have recently engaged in information gathering activities with respect to consumer

product tracking, traceability, and unique product identifiers. Outcomes from those

activities may also help inform the Working Party’s initiative. The Working Party has

been particularly focused on:

• The types of useful information that could reasonably and universally be

provided on consumer products to assist in tracking and traceability; and

• The potential for a uniform and globally recognised approach to its display.

3. This document provides an analysis of input received from the February 2014

questionnaire as well as other useful information from individual jurisdictions. It also

proposes conclusions that could become the basis for a set of good global practices.

Comments on this document from non-government stakeholders would be appreciated

and should be forwarded to the OECD (STIConsumerProductSafety@oecd.org) by May

30, 2015.

DRAFT

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GLOBAL TRACKING/TRACEABILITY

INFORMATION EXERCISE

Template for a Global Practice

Background

1. The International Consumer Product Safety Caucus (ICPSC) initiated a Global

Tracking/Traceability Exercise during September 2009 as a joint assessment among the

staffs of several consumer product safety authorities. The project flowed from the ICPSC’s

Stockholm Conference on Product Traceability and Tracking Labels on September 10 of the

same year, in which regulatory staff from 18 jurisdictions participated. The goal of the

project has been to explore new and useful ways to help consumers, regulators, and affected

economic operators to correctly identify a consumer product when there are concerns about

its safety, while concurrently understanding the relevant and necessary facts related to its

production. An underlying objective has been to identify tools and approaches with the

potential to be useful on a global basis. The OECD Working Party on Consumer Product

Safety followed the ICPSC’s work closely and it was agreed between the two groups early

in 2014 that the project would benefit by being absorbed into the Working Party’s

programme, where it now resides.

2. For regulators in particular, the initiative also has explored ways to better

understand the facts relevant to a specific product’s supply chain. Participants looked into

how supply chain traceability information, which is often generated by, and accessible only

to, industry operators, could be made more accessible to consumers, regulators, and affected

economic operators. Push chairs, also known as baby strollers, were selected as a model

product to visualize the possible application of this initiative. The product was chosen due

to the greater vulnerability of the population associated with the product (small children),

its widespread use, the sufficiency of product surface area, i t s r e l a t i v e l y l o n g

d u r ab i l i t y , and the minimal financial impact on industry and consumers due to the

small cost percentage for the tracking and traceability marking relative to the cost of the

product.

3. The participants considered possible characteristics of a tracking and traceability tool

that would have global recognition and utility for consumers, regulators or enforcement

authorities, and industry. Expressed as a graphic representation, such a tool could

include marking(s) that would provide consumers with the information necessary to

identify a product that has been the subject of a public announcement or to enable them

to describe accurately to safety authorities a product of concern. The representation also

could contain information that regulators might exploit to describe hazardous products

accurately in announcements to consumers, to each other, and to other economic operators.

Related information that could help regulators trace the origin of the product, its distribution

chain, and ideally key components, would be extremely valuable.

4. Based on their inquiries, the participants concluded that the ideal tracking/traceability

information would be represented as a globally recognized unique identification mark or

code for a specific product as the product exists when delivered to consumers. It should be

easy to find on the product and/or packaging. Under the best possible circumstances, this

unique product identifier (UPI) mark or code would be supported by a data system with a

mechanism for: 1) anyone to look up the mark or code and match it to a product, and 2) for

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regulators to access non-public information about the product, such as the actual

manufacturer (in the case of privately labeled goods), manufacturing site identification, and

supply chain information.

5. Economic operators in a consumer product’s manufacturing and distribution chain

may also benefit from globally understood UPIs on products to identify and isolate

hazardous products and to understand factors that may have contributed to hazards in

other products. The Working Party recognizes that some manufacturers and retailers already

operate sophisticated systems for internal production, distribution, and inventory

management. However, this is not universally true. A l s o , they may utilize proprietary1

systems that are not understandable to parties outside the enterprise or its network of

authorized commercial partners. Moreover, if a product leaves the intended distribution

chain as surplus material or due to bankruptcy, reconditioning, or second-hand resale,

proprietary tracking systems may be meaningless to the unanticipated down-stream

economic operators, impeding their ability to react effectively to product safety issues.

Likewise, these operators would have limited capacity to provide meaningful information

about the product’s history to regulators.

6. In addition, the participants are of the view that in order for UPIs to provide

consumers with the information necessary to identify a product that has been the subject

of a public announcement, or to enable them to describe accurately to safety authorities a

product of concern, at least some portion of the identification coding should be in human

readable form rather than exclusively in code that cannot be interpreted or symbols that are

meaningless in human language. For these several reasons, the participants have not viewed

proprietary systems as practical solutions for meeting the objectives of this initiative.

7. During February 2014, the Working Party published an update on the tracking and

traceability project and requested input on the feasibility of specific practices aimed at

improving tracking information on consumer products.

8. NOTE: Throughout the course of this initiative, participation by representatives from

the various jurisdictions has not carried with it any implication that any of the jurisdictions

will adopt the project’s final recommendations or findings, nor has consensus carried any

formal connotation.2 Neither has the Working Party contemplated efforts toward an

international instrument implementing the outcome. This Working Party document carries

these same caveats.

Underlying Considerations Favoring a Global Practice

1 As used here, “proprietary” means the use of formats, coding, media, symbols, etc.

unique to a specific enterprise and not aligned with an international product identification

standard. 2 The views expressed in project discussions and documents have been those of staff and

should be considered informal. They do not imply endorsement, in whole or in part, by any

jurisdiction’s leadership as a basis for current or future policy making, nor do they

necessarily track with the current or contemplated requirements of participating

jurisdictions. As used in project documents, “consensus” refers only to topics, questions,

and potential solutions deemed useful for exploration in the context of this exercise. It does

not imply that any approach, conclusion, or area of specific consideration is being

contemplated by any of the participating jurisdictions.

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1. The Working Party’s understanding of the term “tracking and traceability” is

consistent with the definition of traceability as used in ISO 9000:2005, definition 3.5.4: the

ability to trace the history, application or location of that which is under consideration.

Traceability can relate to:

the origin of materials and parts,3

the processing history, and

the distribution and location of the product after delivery

2. Some jurisdictions have rules in place that require specific tracking and traceability

information on consumer products and/or their packaging.4 Typically, the required

information allows regulators, consumers, and other stakeholders to read the origin of the

product, as well as its production cohort. Some rules also require that the label carry the

name and address of the legally responsible economic operator in the jurisdiction in which

the product is sold. In addition to labeled information, some jurisdictions either require or

strongly encourage the responsible economic operator to compile and maintain a product

technical file that will permit regulators swift access to information about the supply chain,

components, materials, and testing information. Some economic operators may choose to

reference UPIs related to those product files. Taken together, these practices can facilitate

access by the public and regulators to a minimal level of product information immediately

(where the practice exists) and for regulators, to more detailed information after a varying

amount of time following an official request (depending on legal authorities and cooperation

from the enterprise involved).

3. The lack of uniformity in approaches across jurisdictions makes it unrealistic at this

time to consider a global requirement for a broad set of tracking and traceability information.

For that reason, the Working Party is focused on solutions that complement rather than

compete with, or conflict with, existing rules.

4. The lack of a universal, government-mandated product coding system that serves as a

UPI has been a significant point of discussion in the context of this initiative. The

Harmonized Commodity Description and Coding System (HS) managed by the World

Customs Organization is perhaps the closest global mandatory scheme. It comprises about

5,000 commodity groups (including many consumer products); each identified by a six digit

code, arranged in a legal and logical structure and is supported by well-defined rules to

achieve uniform classification. Use of the system to file customs documentation is required

by more than 200 countries and economies as a basis for their customs tariffs and for the

collection of international trade statistics. Over 98 % of the merchandise in international

trade is classified in terms of the HS. Although HS is useful to enhance tariff revenues

3 During the course of this initiative there have been discussions of the potential value to

regulators in obtaining information about component materials in an expedited manner via

global tracking and traceability solutions. However, the capacity to exploit this potential is

not specified as a performance characteristic in the proposed Template for a Global Practice

put forward in this paper. 4 In the United States, children’s products require tracking labels: 15 U.S.C. §2063(a)(5)

In the European Union, see the General Product Safety Directive 2001/95/EC , Article 5)1(a).

Also sectoral rules apply. The model is set out in Annex 1 to Decision 768/2008.

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collection, it cannot provide the granularity needed to ensure accurate identification of

millions of unique products as they appear at retail.

5. Recognizing that current practices by some jurisdictions to require the display of

tracking information on a product are intended to maximize local utility (local language,

address of local company, etc.), the participants have focused on the value of global UPIs as

tools to positively identify a product anywhere in the world and to access relevant company

and production information associated with the product. They have also considered that the

tracking tool’s underlying coding system, as well as its visual representation should be based

on a widely used international standard that can deliver specified performance

characteristics. Global commercialized systems based on international standards for

managing and displaying such information (in characters or symbolically) already exist and

are used widely in industry. Their widespread use minimizes the potential administrative

costs for governments since adoption of an existing industry standard would make the

creation and deployment of a new system unnecessary. The fact that industry is increasingly

adopting such global systems is a major consideration in the participants’ assessment that this

initiative does not suggest a new and unreasonable cost burden on medium-size and large

companies engaged in international trade. The cost burden for small companies needs to be

considered carefully, with particular regard to product value, durability, and international

sales.

6. One such global UPI system is that managed by the product identification standards

developer GS1.5 Its Global Trade Item Number (GTIN) system contains approximately 14.5

million registered products, all of them assigned a unique product identification number. The

value of a UPI in tracking globally traded items can be better appreciated when considering

that at the time of this paper’s publication, over three million products with assigned GTINs

are distributed in multiple jurisdictions. For example, this allows consumers, regulators, and

economic operators to know with a high level of certainty (counterfeiting issues

notwithstanding) whether the product being examined in jurisdiction A is the same product

that was recalled in jurisdiction B. In the case of a safety concern, this knowledge can make

all the difference in directing regulators to obtain key production and distribution information

about the right product at the right time. Regulators may be able to gain access to data on file

with the UPI management organization covering production facilities, key components,

testing history, and the distribution chain associated with a registered product.6 In its

comments to the Working Party’s February 2014 paper, the Business and Industry Advisory

Committee (BIAC) noted that:

5 From the beginning of this project, the participants have queried available sources to

determine which global standards development organizations have developed UPIs in

widespread use by industry for a large number of consumer products. To date, the

participants are aware of no standards developer fitting this description other than GS1. For

this reason, the Working Party relies heavily on information from GS1 to inform its

discussions. It would welcome input during the comment period from other global standards

developers whose development processes and UPIs are consistent with those discussed in this

paper. 6 The prospect of regulators gaining access to production information is complementary to

the other benefits of UPIs cited in this paper but access to such information is not a

performance characteristic called for in this document.

6

Allowing authorities to have a specific and restricted access to details about the

product is of interest for both authorities themselves and industries, and also

consumers that benefit of an improved visibility and smoother controls.

GS1 is developing partnerships and agreements with authorities at national,

regional and international levels to improve efficiency in controlling activities.

For instance, GS1 has collaborated with the World Customs organisation (WCO)

opening its standards to the IPM system created by the organisation. This

partnership has increased efficiency in control activities, has the information

given by the GTIN automatically into the IPM systems helped customs officers to

improve their efficiency in controlling and fighting counterfeiting. For companies

using GTIN, it improved the duration of controls. Other GS1 partnerships with

customs authorities are happening for instance in New-Zealand and in Malaysia:

International standards that define other aspects of the supply chain are also

available. GS1 for example developed GS1 Global Traceability Standard (GTS).

It is the framework for full chain traceability that enables to trace back to

manufacturers of certain components. Various models to share information are

possible (4 models including one up one down).

7. It should be noted that practices to maximize exploitation of UPIs figured prominently

in the October 2013 Final Report of an Expert Group on Product Traceability prepared for the

European Commission.7 The Group, which also was facilitated by GS1, concluded its work

with seven key recommendations aimed and assuring that European regulators and

consumers can respond appropriately to product safety issues:

(1.) Economic operators should label their consumer products at least with a product

identification code and contact details of the responsible economic operator.

(2). Economic operators should automate their traceability system by using data capture,

data recording and data exchange technologies with applicable global standards.

(3.) Economic operators should get trained on traceability in order to be aware of

traceability benefits, understand best practices and get the knowledge to choose and

implement the most relevant tools to automate traceability within their organisation.

(4.) Traceability assessment exercises should be conducted across the chain with the

cooperation of market surveillance authorities and trade associations.

(5.) Information about how to use barcodes / product codes to get additional information

should be included in RAPEX [rapid alert system] trainings for market surveillance

authorities.

(6.) Best practices for market surveillance authorities should be developed for best use of

available information when products are crossing borders within the EU, including real

case studies.

(7.) Consumer associations should raise awareness on the importance of product

identification and inform consumers on possibilities to alert authorities on suspicious

products.

7 http://ec.europa.eu/consumers/archive/safety/projects/docs/20131023_final-report_product-

traceability-expert-group_en.pdf

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Although points 5 and 6 are unique to the European product safety system, the other

recommendations directly support the direction of the Working Party’s initiative on global

tracking and traceability.

8. In May 2013, the U.S. Consumer Product Safety Commission (CPSC) published a

Notice of Proposed Rulemaking dealing, in part, with a proposal to require electronic filing of

certificates for regulated imported consumer products. The CPSC notice flags the importance

of UPIs in helping regulators to understand exactly what product will be entering commerce

if admitted by customs.

The existing rule requires: “Identification of the product covered by the

certificate.” Proposed § 1110.11(a) would state that each certificate must contain

the information described therein, and then list each piece of information as

numbered items 1 through 10, under proposed § 1110.11(a). Thus, proposed §

1110.11(a)(1) would incorporate the requirement to identify the product being

certified, but it would broaden the nature of the “product” that can be covered by a

certificate to include component parts as well as finished products. The proposed

rule would require the certificate to state whether it covers a finished product or a

component part to assist with enforcement and to clarify for all other parties the

scope of the certificate.

Proposed § 1110.11(a)(1) would further state that “[a] model number, style, or

other unique identifier of the product should be provided, if any, along with a

description of the finished product or component part. Certifiers may also include

an identifier, such as a universal product code (UPC), a global trade item number

(GTIN), or other identifying code that may assist with product identification.” This

clarification is intended to provide guidance on the type of information that would

be considered to be identifying information for a product. Providing a model

number or style number, if they exist, would be the most useful way for the CPSC

to identify the product, along with a narrative description of the product. Certifiers

may also provide a stock-keeping unit, or SKU, to assist in product identification.

Additionally, the CPSC is aware that many manufacturers use codes for purposes

of product identification, such as UPC codes and GTINs. This type of information

is also useful for CPSC to identify products. Certifiers would be encouraged to

include any type of identifying code on the certificate, if it would aid in product

identification. UPCs and GTINs are examples of identifying codes. Stakeholders

are encouraged to comment on whether other types of codes should be stated

specifically in the codified text. Although harmonized tariff codes may be placed

on a certificate, they are insufficient, alone, to identify a product on a certificate.

Similarly, a registered identification number, or RN, on wearing apparel, alone, is

insufficient to identify a product on a certificate. An RN is a number, assigned by

the Federal Trade Commission, which identifies a business, and does not

distinguish products. This type of information can be used in conjunction with

other identifying information to identify a product adequately on a certificate but is

not sufficient by itself to identify a product.8

8 http://www.cpsc.gov/en/Regulations-Laws--Standards/Federal-Register-

Notices/2013/Proposed-Rule-Certificates-of-Compliance/

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9. The CPSC’s proposed rule seeks to take advantage of the utility of UPIs to customs

authorities, regulators, and economic operators when they are associated with consumer

products at importation and while in U.S. commerce. Although the CPSC’s proposal focuses

on information to be provided on a certificate, the value of correctly identifying a product at

the port is difficult to overstate. If customs authorities and regulators have a high level of

certainty that the contents of a container is known product with a pristine record for safety,

the movement through customs should be unimpeded. UPIs make an important contribution

to that determination. If authorities are on the lookout for a hazardous or noncompliant

product and they have a UPI to reference, then the processing of somewhat similar products

carrying different UPIs should not be delayed (all other factors being equal). The relatively

modest investment9 in a UPI by a brand owner saves time and money for all parties involved

and allows government authorities to focus on higher risk shipments. The participants note

that increased efforts are needed to combat the use of counterfeit UPIs including bar codes.

This is necessary to mitigate the risk of admitting a hazardous product carrying the

identification of a safe and genuine article.

10. In the Working Party’s view, a UPI to be used as a global tracking and traceability

tool with value to consumers, regulators, and other economic actors should be based on a

global standard developed through an inclusive and transparent process open to all

stakeholders.

The UPI should have the following performance characteristics:

The UPI should use characters (alpha and/or numeric) that are human readable.10

The coding should identify the unique product as delivered to consumers.

Anyone should be able to determine, at minimum, the brand owner and its registered

location associated with a UPI, and ideally, what product is represented by a UPI, via a

search on an easy-to-locate public web site.

11. Participants in this exercise have discussed the value of describing a particular space

on the product/packaging, where the global tracking information would always be located

and which would always be recognizable especially by consumers but also by regulators or

enforcement authorities. Some have advocated that such a space, whether defined by colour

or shape or outline, could help clarify which mark, code, symbol or characters found on a

product might be helpful tracking information. For example, many products now carry

multiple bar codes. A number of participants thought that a uniform target area might be

useful to consumers but that the concept should be thoroughly shared with stakeholders,

to understand also how they would see the cost and the benefit from their perspectives.

9 By way of example, the cost of obtaining a registered GTIN from GS1 varies slightly by

country and by factors related to the applicant’s annual turnover. In general terms, a

registration may normally be obtained for significantly under U.S. $100.00, not including

membership fees. In general terms, the cost impact for a global brand will be far less

significant than for an SME with limited distribution. 10 Exclusive use of alpha and/or numeric characters is not being advocated here. But for

maximum value to consumers without technology to assist in reading other types of coding,

the UPI should always be represented in visible alpha and/or numeric characters.

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12. Comments from industry indicated that using a uniform target area would require

costly redesign and might not be the most practical solution for ensuring that consumers

(and others) can quickly identify the global UPI. Some questioned whether there truly is a

need to call attention to the location of the UPI, since UPIs are widely used and

recognized already. Some comments noted that it is a minority of consumer products that

carry multiple bar codes or other coded tracking information. Only one commenter

proposed an alternative to a target area, suggesting the use of DotCode (coded information

in a form organized by the placement of dots in a matrix). However, the participants in this

project note that specifying a specific machine (only) readable system departs from the goal

of using symbols that humans can read without assistance.

13. In considering the argument that UPIs are on most products and that multiple

tracking codes are rare, the Working Party observes that most products – including many

durable products – do not carry a UPI permanently affixed to the product. In most cases,

the UPI is on a tag or the packaging and is removed when the product is purchased, thus

eliminating its long-term value as a product identifier in the event of a recall. With regard

to how many UPIs might be on a product, the Working Party notes that the incidence of

multiple printed bar codes appearing on a product is great even if that does not represent

the majority. In a campaign to educate consumers about UPIs, which would logically

follow implementation of the practices advocated by the Working Party, a simple means

of flagging the UPI will be essential to assuring consumers that the tool is easy for them to

find and use.

14. In reconsidering how the goal of flagging the UPI might be met without specifying

a recognizable target area, the Working Party is considering an alternative that would call

for a simple graphic to clearly identify the global UPI. The illustration below shows an

arrow, which is the working solution being proposed. Comments on this paper might

identify an alternative symbol or other simple flagging tool as more appropriate for global

use.

In any case, an added graphic must be placed outside the mandatory “quiet zone”

surrounding the data carrier (bars, dots, matrix, etc.). Taking into account the growing

amount of information and data carriers required by regulators and retailers, the Working

Party is of the view that flagging the UPI will provide significant benefits to consumers.

The participants also recognize that many products have little or no space available for a

UPI on the products themselves but they also note that strollers and other larger durable

products do not have this limitation.

15. Participants recognized early on in the project that local language requirements and

other labeling rules in a given jurisdiction often will require the use of product identification

tools or other tracking and traceability markings other than a global UPI as discussed in this

initiative. There was a consensus that it would be ideal for the globally recognizable UPI to

be located in close proximity to locally required traceability markings, where practical.

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Conclusions

A. The Working Party puts forward the following six proposals as a template for a

global practice.

1. Brand owners should place permanently11

on certain classes of consumer products

and also on disposable packaging, or if product surface space does not allow, only on

the packaging, a UPI that meets the performance characteristics put forward in this

paper. This is of greatest importance with durable consumer products and products for

vulnerable populations.

2. The UPI should be based on a global standard developed through an inclusive and

transparent process open to all stakeholders.

3. The UPI should be flagged by a standardized arrow shape pointing in its direction in

close proximity.

4. The globally recognizable UPI should be located in close proximity to l ocally

required traceability markings, where practical.

5. Consumer education campaigns about the UPI should be launched in jurisdictions

where these global practices are implemented.12

6. Use of the UPI as described is not a substitute for the labeling requirements of

individual jurisdictions.

B. Following a review of comments on this paper, the Working Party will publish its final

Template for a Global Practice for the use of UPIs as tracking information on consumer

products.

C. The Working Party proposes that the global practice undergo a test period of two years,

during which baby stroller / push chair brand owners would be encouraged to comply

voluntarily with the Template for Global Practice.

D. At the end of the test period, the Working Party should work with brand owners who

have participated, as well as with other stakeholders, to evaluate the results of the exercise

with the aim of identifying areas for improvement, including any appropriate next steps.

E. Comments on this document from n o n - go v e r n m en t a l stakeholders would be

appreciated and should be forwarded to the OECD (STIConsumerProductSafety@oecd.org)

by May 30, 2015.

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It is noted that various jurisdictions define permanent marking differently in reference to

information labeling on products. A workable definition will be needed for this initiative. 12

The nature of such campaigns and the role played by various actors will be dependent upon

the circumstances in each jurisdiction. It may be useful for the Working Party to develop

some common material for use by participating jurisdictions.

Compiled Comments from the Private Sector

February 2014 Questionnaire

Working Party on Consumer Product Safety

Global Tracking and Traceability Exercise

General Comments

JPMA

As a practical matter CPSIA Tracking Identification requirements are

already in place for children's products so we are already doing that

with our products.

In the private sector, major retailers and the Military already barcode

tracking and are experimenting with passive RFID tracking systems for

freight forwarding, inventory management and logistical distribution

tracking (WalMart and DOD).

As a regulatory matter we tend to disfavor a "one system" approach,

electing for marketplace flexibility in which tracking data is disclosed

and which technologies are used. In this regard we favor maximum

discretion instead of limiting technological advancement and

availability of competitive choices.

Questions for Stakeholders

1. What international standards are available to support a combination

machine readable and human readable (visual) product marking that

provides a unique consumer product identifier specific to the product’s

configuration? Are there also international standards available that in

addition would allow the identification of the products’ specific

contents of components, and its specific retail packaging? Do the

standards mentioned above support a web based, typed-entry look up

function for the human readable product marking that would allow

consumers to view basic information about the product and it origin?

Domino:

We work closely with GS1, the global standards body for auto ID, who

have a highly sophisticated interoperable system using machine and

human readable codes to give a unique consumer product identifier

specific to the product’s configuration. The predominant machine

readable code in use is ECC200 2D Datamatrix where ISO15415, which

superseded ISO16022, is able to give very detailed quality standards

which will then reflect the likely performance of any identifier. An

excellent example of a system which is being developed to provide this

level of functionality is the European Falsified Medicines Directive

which has been transposed into EU law (EU-Directive

2011/62/EU).The result is that within three years all Pharmaceutical

products across Europe will have a unique identifier on every pack that

can be verified at point of dispensation. Domino has worked closely

with a number of the stakeholders of this initiative and can provide

much more detailed information if needed.

GS1:

GS1 standards are voluntary, consensus-based, global standards that

support the efficient identification, capture and sharing of information

regarding products, locations, assets, and services. Based on our

experience, we will answer your questions by presenting our relevant

standards.

First we note that an effective product marking combines two elements:

- an identifier: for GS1, the product identification is the GTIN standard

identifying a specific product.

- a carrier: a graphic symbol (such as barcodes) or an RFID tag that can

be human and/or machine readable.

The information embedded can then be efficiently shared through

databases and web-based tools.

The following is a brief overview of the 3 critical steps in the system:

identification, capturing and sharing of information.

Identification: standards for machine and human readable marking

GS1 Identification Numbers are used to uniquely distinguish all

products (trade items), logistic units, locations, assets, and relationships

across the supply chain from manufacturer to consumer. The Global

Trade Item Number (GTIN) is used to identify each specific

consumer product.

Each GTIN is built to adhere to GS1 standard specifications and is

globally unique. This means the GTIN identifies a specific product

unambiguously and worldwide. Additionally, it enables a product to be

traced back to the brand owner who assigned the GTIN to that product.

A GTIN is composed of a GS1 Company Prefix and the Item (product

or service) reference number. The allocation of each GTIN is

decentralized meaning the GS1 Company Prefix is allocated by a local

GS1 organisation to the brand owner and the Item Reference is then

allocated by that company.

It is important to note that a GTIN allocated by any GS1 organisation is

valid worldwide and that the GTIN itself does not carry information

such as the country of origin. Companies can share descriptive

information about GTIN with their trading partners using standards like

the Global Data Synchronisation Network (GDSN).

The GS1 GTIN standard is recognised by the ISO/IEC 15459 series of

standards, which specifies identification rules for logistic units, items,

returnable assets and groupings. The standard provides for Issuing

Agencies Codes (IAC) that creates uniqueness between identification

schemes from various bodies by prefixing the identifiers with a code

assigned by a registration authority. The IAC 0 to 9 have been assigned

to GS1. This implies that, in the context of this standard, any identifier

starting with these numeric digits is automatically recognised as a GS1

identifier.

Additionally, GS1 global identification standards enable a more

granular level of product identification and product tracing by adding a

batch/lot number, best by / use by date or a serial number (sGTIN) to

identify individual units. For example, 2 cases of Product ‘X’ can be

easily distinguished in the supply chain even though they share the

same GTIN, because each has its own serial number (serialized GTIN).

The serialized GTIN creates the ability to distinguish each individual

case from another as its assigned identity (via serialized GTIN) is

globally unique.

Capture: Human and machine readable standards

GS1 Data Carriers are capable of holding varying amounts of data to

accommodate additional needs beyond GTIN such as batch/lot

information and expiration dates. They are human and/or machine-

readable. Indeed, having a human readable identifier next to a machine

readable identifier is widely accepted as best practice to minimize

logistical concerns such as carrier damage, etc.

The main carriers are shown below. 1D and 2D carriers with both

machine and human readable information (please note that this is not

the exhaustive illustrations of GS1 data carriers).

Another data carrier is appearing using Radio frequency technology to

capture the data. GS1 EPCglobal standards are designed to facilitate the

flow of products and related business data across the supply chain and

they define how that data is communicated between supply chain

stakeholders. With EPCglobal, new technologies are added to the GS1

suite of standards, namely Radio Frequency Identification (RFID) and a

distributed data repository concept (EPCIS). They make use of the

Electronic Product Code (EPC), which is a universal identifier that

provides for unique identification for every physical object anywhere in

the world. The EPC can be used at the level of item, logistics unit or as

an asset identifier. The GS1 identification keys for item instances can be

used as EPC’s.

As explained above, the GTIN provides the unique identification

number to a product. It is the key to accessing more detailed

information related to this product, including components and specific

retail packaging. This additional information can be accessed via GS1

standards to Share data.

Share: web based, typed-entry look up function tool

GDSN

GS1, with guidance from the industry, developed the GS1 Global Data

Synchronisation Network® (GDSN), to synchronise the master data

held in a manufacturer’s internal database (data source) with their

customers (data recipient). It provides a one to many connection

whereby a manufacturer can keep all of their customers updated with

the latest product data anywhere in the world. The GS1 Global Data

Synchronisation Network connects trading partners (manufacturers,

retailers, distributors, hospitals, wholesalers and group purchase

organizations) to the GS1 Global Registry®. This connection is made

via a network of interoperable GDSN-certified data pools2.

The GDSN is a secure mechanism to access trusted product information

in an automated fashion. It effectively answers the B2B challenges in

communicating and accessing updated information on a product and

allows for a more efficient flow of product information critical to

business success.

The GDSN is built around the GS1 Global Registry®, GDSN-certified

data pools, GS1 Global Product Classification and the GS1 Data

Quality Framework, which when combined provide a powerful

environment for secure and continuous synchronization of accurate

product master data.

This network allows companies to access certified Data Pool services of

their choice and in their chosen language. Types of information

communicated through GDSN include: GTIN, classification, descriptive

information, size and weight, brand name, ingredients, allergens, net

content and country of origin statement among many other type of

master data related to the product and the manufacturer.

It is important to understand that GDSN is primarily designed for

Product Master (static) data. Should the information about the

components be dynamic, e.g. different from one batch to another, then

other GS1 standards such as eCOM (GS1 Despatch Advice message -

bilateral exchanges, linked to the business transaction, for one up one

down traceability) and EPCIS (EPCIS is a distributed data repository

concept that allows enhanced visibility is achieved by revealing both the

whereabouts and status of trade item instances and other physical

objects) can be used to communicate the appropriate information.

Finally, the use of GS1 Global Data Dictionary ensures that all data

definitions and formats are consistent and facilitate the efficient

exchange of information.

GEPIR

GEPIR3 (Global Electronic Party Information Registry) is a unique,

internet-based service that connects the various GS1 Member

Organisations across the world and provides access to basic contact

information for brand owners that are members of GS1. By simply

typing a GTIN, GLN, SSCC (Shipment numbers), or the name of an

organisation into the GEPIR webpage, anyone can find the owner and

contact information for whom the license to create GS1 Keys has been

assigned. This is known as the GS1 Global Company Prefix. Click this

link4, for a 2-page factsheet about GEPIR along with a demonstration

of GEPIR in annex II.

GS1 Source

GS1 Source is a framework for sharing product information in

consumer-facing digital channels. It is standards-based, scalable and

interoperable. Companies can use GS1 Source to share information

about their products on the cloud to reach consumers.

Application developers can then integrate this product data in their web

and mobile applications which often provide a typed-entry look up

function service.

In conclusion, interoperability, made possible by identification, data

capture, and data exchange standards, allows product information to

flow through the supply chain to each intended recipient in an easy and

secure manner.

NGPI

In addition, GS1 and the FMCG industry (through the Consumer Goods

forum5) have partnered on the Next Generation Product Identification

(NGPI). NGPI is an innovation initiative to deliver more and accurate

consumer information, both on-line and in store, without causing major

disruption to the supply chain or POS. Industry leaders are developing

an information strategy for the next 10+ years and, with careful

consideration to associated bar code choices. Although 50 use cases

have been identified, the priority areas remain focused on the consumer

and providing greater granularity of information… anytime,

anywhere… and, standards development has begun. As this new

capability is soon created and unleashed, industry will continue to

reassess other use cases for both business and consumer in line with

their vision

BIAC

A product marking combines 2 elements:

-an identifier:

International standards that combine machine and human readable

product marking exist and are even largely used globally. ISO /IEC

15459 provides the general framework. It a series of standards

specifying identification rules for logistic units, items, returnable assets

and groupings. The standards make provision for Issuing Agencies

Codes (IAC) that create uniqueness between identification schemes

from various bodies by prefixing the identifiers with a code assigned by

a registration authority.

Between many existing standardised identifier, there are the GS1’s

GTIN (Global Trade Item Number) - recognised by the ISO/IEC 15459,

and the Vehicles Identification Number (VIN) for the automotive

sector.

-a carrier:

It is a graphic symbol or an RFID tag that can be human and/or machine

readable. ISO has developed standards for carriers such as barcodes, for

which standardization bodies developed specific standards. Some

organisations have developed their own standards for specific carriers

such as QR Code and dotCode.

Web-based type entry look up tools exist. For instance, GS1 has

developed 2 different tools:

-GEPIR is the more ancient one. By simply typing a product bar code

number into GEPIR webpage, anyone can find the owner of that

barcode's contact information (physical location numbers and Shipment

numbers can also be used as search criteria).

-GS1 Source is a framework for sharing product information in

consumer-facing digital channels. It is standards-based, scalable and

interoperable. Companies can use GS1 Source to share information

about their products on the cloud. Application developers can then

integrate this product data in their web and mobile applications which

often provide a typed-entry look up function service.

2. What international standards are available to support a machine

readable product identification system (combined with the human

readable function described aboved) that could allow regulators

restricted, web-based access to additional details about the product

registrant of record or manufacturer? In addition, are there

international standards that also defined other aspects of the supply

chain, such as the manufacturers of certain components used in the

product?

DOMINO

There are a number of standards available, in addition to those

mentioned above, that describe a system to allow regulators restricted,

web-based access to additional details about the product registrant of

record or manufacturer these include ISA95, for example, which covers

the management and transfer of data within a repository system.

Domino is very happy to discuss more details on this as needed.

GS1

Restricted access to authorities: public-private partnerships using GS1

standards

Allowing authorities to have a specific and restricted access to details

about the product is of interest for both authorities themselves and

industries, and also to consumers, who benefit from improved visibility

and smoother controls. GS1 is collaborating with various public

authorities.

Customs organisations (Customs) worldwide face mounting challenges

when it comes to facilitating cross-border trade for global businesses.

To avoid delays in product clearance while protecting citizens and the

environment, Customs and other government organisations (OGAs) are

exploring how global standards can be used in their cross-border

product management processes. Likewise, businesses are becoming

aware of the mutual benefits that standards bring to their organisations

and the global supply chains in which they operate.

Both Customs and industry have similar needs to reduce the

complexity, time, and costs related to importing and exporting goods.

With visibility into products arriving at borders, government

organisations and businesses can improve security measures for

consumer safety and gain efficiencies when governments can identify

low-risk, repetitive products through the use of global standards.

At these “intersections of need,” GS1 Member Organisations (MOs) are

Strategic Partner to help facilitate discussions and explain the value of

standards already in use in the supply chain as a relevant contributor for

safer, more efficient international trade.

WCO / GS1 partnership

In 2012, GS1 signed a Cooperation Agreement with the World Customs

Organization (WCO) to address concrete areas of collaboration with the

WCO on the subject of Anti-Counterfeiting for the next two years and

beyond by integrating the GS1 System into their IPM (Interface Public-

Members) tool. IPM is an online and mobile application enabling right

holders to provide Customs officers with real-time data on their

products. Customs officers can access this information anywhere in the

world via a simple and secure interface available in their national

language.

In 2013, WCO and GS1 reinforced their cooperation and launched the

new mobile IPM building on IPM’s initial success. This version offers

new features such as the possibility to use mobile devices to scan

industry standard GS1 barcodes found on millions of products, enabling

the search of the products database in a more time-efficient manner.

Two other examples of partnership with customs authorities are

happening in New-Zealand and in Malaysia:

-New Zealand’s border protection agencies (Customs and the Ministry

of Primary Industries) are working with industry to implement a Joint

Border Management System (JBMS) that provides a “single-trade

window” through which to speed goods transit and increase visibility

for risk management purposes. GS1 Standards have been identified as

important to support in the JBMS, and GS1 New Zealand is a

recognised partner.

- In Malaysia, Customs is working closely with industry stakeholders,

especially Malaysian manufacturers, to replace the current Customs

electronic information system and National Single Window (NSW)

system with a new system called “Ubiquitous Customs” or uCustoms.

The Hong Kong Customs is moving to a Single Window automated

process, investing in risk assessment of inbound and outbound

shipments.

GS1 US – ITDS Pilot project

GS1 US has worked with members of the US International Trade Data

System (ITDS) Product Information Committee to explore how the use

of global e-commerce standards – as part of a rigorous IT strategy – can

improve product visibility across borders, improve consumer security,

and deliver significant cost savings to industry, government, national

regulators, and customers alike.

In 2011, the ITDS Product Information Committee recommended three

principal strategies to help solve this challenge:

Create a global language

Identify products by brand and model

Leverage product catalogs

These strategies were put to the test via industry pilots. The Committee

selected a sample of diverse product sets: toys and games (trade partner:

Hasbro), cut flowers (trade partner: Association of Floral Importers of

Florida), and meat and poultry (trade partner: Tyson Foods).

The goal was to improve product visibility and, ultimately, ensure

product safety in categories including toys and games (which

encompasses more than 850,000 products with a declared value of

$14.5 billion imported into the U.S. in 2010).

The pilots showed that industry can be a leader in transforming global

commerce, which in the case of toys and games will help the Consumer

Product Safety Commission (CPSC) reduce consumers’ exposure to

health and safety hazards in products. Use of Global Trade Item

Numbers (GTINs) and Global Product Classification (GPC) codes

reduced the volume of consumer products subject to examination of toy

and game products by 80% or more. More detailed information can be

found here

Standards on other aspects of the supply chain: The GS1 Global

Traceability Standard

GS1 developed a standard to enable operators to standardize other kinds

of information through the supply chain: the GS1 GTS (Global

Traceability Standard). Please note that this is primarily a tool to

support companies’ activities and not specifically designed as a

mechanism to provide authorities with restricted access to information.

GS1 GTS is the framework for full supply chain traceability that

enables trace back to manufacturers of certain components. It defines

common minimum requirements and business rules to be followed

when designing and implementing a traceability system. It is supported

by voluntary business standards internationally accepted and links each

enabling technology (barcode, RFID, EDI) with the relevant GS1

technical standards. Various models to share information are possible (4

models including one up-one down).

Codex, ISO, BRC, IFS, HACCP and FSSC 220057 as well as

regulations define high level requirements for traceability (this is the

“WHAT should be done” aspect), leaving industry to determine the

most efficient and effective methods for compliance. GS1 Global

Traceability Standard provides the “HOW” process to meet these

requirements.

BIAC

Allowing authorities to have a specific and restricted access to details

about the product is of interest for both authorities themselves and

industries, and also consumers that benefit of an improved visibility and

smoother controls.

GS1 is developing partnerships and agreements with authorities at

national, regional and international levels to improve efficiency in

controlling activities. For instance, GS1 has collaborated with the

World Customs organisation (WCO) opening its standards to the IPM

system created by the organisation. This partnership has increased

efficiency in control activities, has the information given by the GTIN

automatically into the IPM systems helped customs officers to improve

their efficiency in controlling and fighting counterfeiting. For

companies using GTIN, it improved the duration of controls. Other GS1

partnerships with customs authorities are happening for instance in

New-Zealand and in Malaysia:

International standards that define other aspects of the supply chain are

also available. GS1 for example developed GS1 Global Traceability

Standard (GTS). It is the framework for full chain traceability that

enables to trace back to manufacturers of certain components. Various

models to share information are possible (4 models including one up

one down).

3. What difficulties or challenges would the potential use of a globally

recognized target area for displaying the product information, whether

defined by colour, shape, outline, or other characteristic, have for

industry? What would be stakeholders’ preferred method for identifying

a globally recognized target area?

DOMINO

It is not necessary to have a target area on packaging as long as there is

only one machine readable code on each pack. The machine readable

code could then contain all of the required information, such as GTIN,

batch, expiry, weight etc… as well as the representation of his data in

human readable. The wide variety of substrates, shapes and colours

would make the standardisation of a target area very challenging. It is

also worth noting that ISO15415 for 2D codes also specifies a minimum

contrast level, this normally requires a black or dark grey code to be

placed on a white background or the inverse of this.

BIAC

One of the key requirements for full supply chain tracking and tracing is

the need to apply data real time to product, i.e. the product identifier and

carrier are applied at point of production. This in turn requires the

ability to directly print the machine and human readable markings. As a

result the creation of a globally recognised target area is constrained by

a number of printing related factors, namely; the speed of production,

the size and space available on the packaging to carry a target area and

the need to ensure sufficient colour contrast to enable machine

readability. Creating a unique shape is also likely to be difficult to

achieve given that most standard data carriers are rectangular in shape,

thereby not providing sufficient uniqueness for consumers to recognise

them.

According to some BIAC Members, one possible option is to use the

unique visual characteristics of the DotCode data carrier as the global

target area. DotCode is open source, whilst being proven to support

printing at high production speeds. It is already being used in some

industries solely for tracking and tracing, as opposed to other more

common carriers which are used for multiple purposes e.g. bar code,

data matrix. There is a clear opportunity for DotCode to be adopted as

the unique identifier for a globally recognised target area before its use

becomes common place.

TIA

While seemingly simple, in reality, it is frequently difficult to provide

useful information with limited area on a toy. The concept of the

consumer having access to manufacturing information in the case of a

recall is a good one, but providing a meaningful level of information

given the often limited space available can be unduly burdensome for

toy manufacturers, and demands a high degree of flexibility in any

requirements.

The scheme outlined in the report goes beyond requirements designed

to ensure compliance with toy safety norms in other countries and

would result in significant costs for toy companies, particularly for

small enterprises. Tracking label requirements already exist in the U.S.

and the European Union, two of the largest markets for toys; adding

another level of traceability is unnecessary and would only be a cost to

manufacturers, and ultimately consumers, with no added safety benefit.

We therefore oppose the proposed tracking label project as a whole and

recommend instead the WP educate consumers on existing traceability

requirements instead of implementing yet another tracking method.

The requirement of a unique UPI for each model of product, and the

printing of the UPI on each product itself would present major burdens

for toy manufacturers. It is understood that the scheme is intended to

improve traceability of product. However, the system contemplated is

overly-burdensome, expensive to implement and would not advance

safety. This would require companies develop unique packaging for

product lines. This is not insignificant when margins are already tight

(with the average cost of a toy $9). Moreover, it is unnecessary for

specific markets to have unique identifiers. For example, consumers in

the U.S. are aware that they are purchasing the product in the U.S. while

consumers in England are similarly aware of the location of their

purchase. A tracking label would not provide additional helpful

information to this regard.

4. How would consumers benefit from the use of a globally recognized

target area for displaying the product and original supplier

identification information and related tracking information on

consumer products?

DOMINO

There would be no benefit above the ability to scan a machine readable

code anywhere (suitable) on the pack and then use this to verify product

authenticity, gain further product information or use the link as a portal

to other information sources.

BIAC

The key benefits are gained when the product, supplier and tracking

information can be securely accessed by smartphone or internet enabled

device. Providing information in purely human readable form is

unlikely to be secure and can easily be counterfeited/copied by illegal

traders. A more secure and robust method of providing relevant data to

consumers would be to utilise the machine readability of the data carrier

within the globally recognised target area. Ideally a combination of

tracking and tracing information plus authentication capability can be

built into the same area and verified by consumers using any internet

enabled device. For consumers this would provide instant access to

verify the legitimacy of the product and whether there is a recall or

other advisory notices from the brand owner they need to be made

aware of.

5. What are the costs and benefits of using or not using tracking labels on

products informing consumers about product identification, the

producer, and where it was manufactured? How can costs or benefits

be quantified?

DOMINO

The use of labels has a very significant cost in both the actual cost of

the label and the negative impact on manufacturing line efficiency that

label application can have. We have found that, as advocated on most

systems being legislated/deployed, that the direct marking of each pack

is the most cost effective and efficient method to achieve the desired

results.

BIAC

There is definitely a benefit to consumers in providing the means to

verify the product identity, producer, etc. purely from a perspective of

consumer protection. The issue in terms of cost is whether a physical

label is used to ‘label’ the product or whether direct to package printing

is utilised. As described previously, direct printing supports real time

data application and is more secure than physical labels. More

importantly the cost of direct printing is significantly cheaper than

physical labels. Printing avoids the cost of each physical label plus the

associate transport, handling and secure storage costs.

TIA

A consumer is not benefited by knowing this information about a toy.

The consumer is benefited by knowing that a toy is safe (i.e. knowledge

that the product meets applicable requirements), the name and contact

information of the responsible party (retailer, distributor, manufacturer,

etc.), and any additional information necessary to determine if the

specific product in their possession is subject to a recall or other safety

alert. In addition, traceability to the origin of materials and parts is

unfeasible and would result in either exorbitant costs or putting

companies out of business altogether.

We respectfully disagree that the place of manufacture be made

available to consumers on a public website. Often times the place of

manufacture is business confidential information that if made public

could compromise well established business relationships. Requiring

this information be made public could further chill the creativity

currently allowed in the manufacturing process.

Also, the detail of the UPI outlined in the report is infeasible for toy

manufacturers to place on their products. Because of the safety labeling

requirements already mandated by several countries (namely the U.S.

and EU, not to mention U.S. states including California and Illinois),

package real estate is already limited. UPI information would not only

be a challenge for manufacturers to implement, it would also distract

from important safety information like warning labels. Along these

same lines, an arrow pointing to the UPI would mislead consumers

when their focus should be on the safety information relating to the

product. In our view, when it comes to labeling, less is more, and safety

information, where needed, is paramount.

Implementing a “one size fits all” labeling program across industries

will not work as a label for a bicycle will be extremely different from a

label for a bouncy ball. Furthermore, production lines vary immensely

even within industries. While one company may organize production by

batches, another company may use purchase orders (PO) instead. A

large company with many production lines may require both a date of

manufacture and the cohort information while a small company with

only one production line may just need to include the date to satisfy

both requirements. As a result, companies will take different approaches

to tracking products and we believe it is extremely important to remain

flexible and allow manufacturers to adopt a tracking label system that

works best for their company.

6. What are the costs and benefits of having tracking information on a

product for authorities including detailed information on the product

supply chain. How can costs or benefits be quantified?

DOMINO

The benefits have been proven to outweigh the costs on systems being

deployed across the globe at the moment and there are a wide number

of benefits including;

Reduction in counterfeit/falsified & contraband products.

Efficient management of product recalls.

The ability to offer consumer engagement.

The use of machine readable codes for the vision impaired.

The ability to link directly, and instantaneously with re-

imbursement, product verification or fiscal recovery systems.

There is an excellent report which was recently commissioned by the

EGA (European Generics Association) on this subject which can be

found at :

http://www.egagenerics.com/index.php/publications/261-kpmg-report-

advice-on-the-implementation-of-eu-directive-2011-62-eu

BIAC

As for consumers, tracking information can enable real time evaluation

of product by law enforcement and customers for goods in transit. This

in turn enables authorities to quickly assess whether product is

legitimate or whether there is an issue with the product, e.g. a recall.

Tracking and tracing also enables authorities to work with the supply

chain to identify and ‘plug’ leakage of product out of the legitimate

supply chain and similarly to prevent illegal or substandard product

leaking into the legitimate marketplace. For highly taxed consumer

products, this can benefit authorities by supporting enforcement against

tax evasion and ultimately enhancing revenue collection.

7. What other recommendations could you make to industry and market

surveillance authorities on best practices to improve product tracking

and traceability for consumer products globally?

DOMINO

I would suggest a review of the systems successfully being deployed in

the Tobacco and Life Sciences sectors would be an excellent idea.

Please let us know if we can help facilitate any discussions, my contact

details are as follows;

GS1

A good example of a regional public-private partnership to develop a

set of best practices is the recent informal expert group on Traceability

created by the European Commission, to which GS1 contributed. The

result of the discussion was published in October 20138.

This group of experts coming from manufacturing industry, retailers,

consumers and authorities shared the best practices they identified in

traceability. Seven recommendations were made to develop best

practices and share experience. It is important to note that these are

voluntary and based on the European environment (legislation, business

obstacles, market structure, etc.).

The recommendations are as follows:

1. Economic operators should label their consumer products at least

with a product identification code and contact details of the

responsible economic operator.

2. Economic operators should automate their traceability system by

using data capture, data recording and data exchange

technologies with applicable global standards.

3. Economic operators should be trained on traceability in order to

be aware of traceability benefits, understand best practices and

get the knowledge to choose and implement the most relevant

tools to automate traceability within their organisation.

4. Traceability assessment exercises should be conducted across the

chain with the cooperation of market surveillance authorities and

trade associations.

5. Information about how to use barcodes/product codes to get

additional information should be included in RAPEX trainings

for market surveillance authorities.

6. Best practices for market surveillance authorities should be

developed for best use of available information when products

are crossing borders within the EU, including real case studies.

7. Consumer associations should raise awareness on the importance

of product identification and inform consumers on possibilities to

alert authorities on suspicious products.

BIAC

The European Commission published in October 2013 a study

developed by an informal and independent expert group on Traceability.

This group of experts coming from manufacturing industry, retailers,

consumers and authorities shared the best practices they identified in

traceability. This best practices are consensus based agreed for the

European market

Seven recommendations have been made to improve traceability. It is

important to note that these are voluntary and based on the European

environment (legislation, business obstacles, market structure, etc.).

The recommendations are as follows:

1. Economic operators should label their consumer products at least

with a product identification code and contact details of the

responsible economic operator.

2. Economic operators should automate their traceability system by

using data capture, data recording and data exchange

technologies with applicable global standards.

3. Economic operators should get trained on traceability in order to

be aware of traceability benefits, understand best practices and

get the knowledge to choose and implement the most relevant

tools to automate traceability within their organisation.

4. Traceability assessment exercises should be conducted across the

chain with the cooperation of market surveillance authorities and

trade associations.

5. Information about how to use barcodes / product codes to get

additional information should be included in RAPEX trainings

for market surveillance authorities.

6. Best practices for market surveillance authorities should be

developed for best use of available information when products

are crossing borders within the EU, including real case studies.

7. Consumer associations should raise awareness on the importance

of product identification and inform consumers on possibilities to

alert authorities on suspicious products.