About

Why "One Step Back"

Art. 18 of the General Food Law requires every food business to know one step back and one step forward in its supply chain. It's the foundation of food traceability, and some version of it is written into every traceability procedure in the country.

But the risk isn't symmetrical. Adulterated honey arrives at goods-in. Deforestation happens at origin. Fraud lives at your supplier's supplier. Recalls almost always start with something you bought, not something you sold. Upstream is where the trouble is, so upstream is where this looks.

There's a second meaning underneath. Art. 18 only ever asked for one step — and that's precisely why traceability keeps failing. Everyone can see their immediate supplier; nobody can see the chain. EUDR exists because one step back was never enough; it wants you to see all the way to the plot of land. That ratchet — from one step to the whole way down — is the story this site follows.

And a third, less clever one: when a new regulation lands and the industry is either panicking or selling something, it's worth taking a step back and working out what actually changed.

What it covers

Six areas. The examples in brackets are illustrations, not the boundary — schemes get renamed, standards get replaced, and new regulation turns up every year. The test is simpler than a list: if it lands on a technical or quality desk in food manufacturing, it's in scope.

• Food safety standards and certification — revisions, clause interpretation, transition deadlines, and what auditors actually look for. (The GFSI schemes and the UK ones: BRCGS, IFS, FSSC 22000, SQF, SALSA.)
• Ethical, social and sustainability schemes — the certifications your customers ask for, how their chain of custody models differ, and what a certificate genuinely evidences versus what people assume it does. (Sedex/SMETA, Rainforest Alliance, Fairtrade, RSPO — and whichever scheme lands next.)
• Regulation and due diligence law — the rules themselves, plus the growing stack of duties behind them. (Deforestation, forced labour, modern slavery, labelling, allergens, diet policy, and the UK/EU divergence running through all of it.)
• Packaging and producer responsibility — recyclability ratings and the fees attached to them, packaging chemistry and food contact, deposit schemes, packaging taxes. (pEPR and RAM 2027, PPWR, DRS, PPT. Flexibles especially, because that's where the pain lands.)
• Ingredient integrity and food fraud — how adulteration actually works commodity by commodity, what your testing does and doesn't prove, and what belongs in a vulnerability assessment. (Dairy powders, herbs and spices, honey, oils, meat speciation, fish. The hotspots move with commodity prices.)
• Environmental and carbon compliance — the obligations arriving through the factory rather than the product. (Waste, refrigerants, emissions, carbon border levies, and the reporting demands cascading down from customers.)

Three kinds of piece, depending on what's useful. What's coming — a regulation or standard revision heading your way, and whether it touches you. How to be ready — walking into an audit against a standard that's already live, knowing what's expected and what tends to get written up. What it actually means — how a fraud works, what a certificate does and doesn't evidence, why a clause exists at all.

Not everything worth writing about is a change. A standard published last month is still new to the person being audited against it next quarter.

Who writes it

I do — a quality professional working in UK food manufacturing. Audits, specifications, supplier approval, and the daily business of keeping a certified site compliant. This exists because keeping up with all of the above is a second job nobody gives you hours for, and everything I could find was either a £140 PDF, a law firm briefing written for lawyers, or a software company's blog with a demo button at the bottom.

Nothing here is for sale. No software, no audits, no courses, no consultancy. When the honest answer is "ignore this for now", that's the briefing you'll get.

What this isn't

It isn't a substitute for the standard, and you shouldn't treat it as one. Nothing written here is a defence at audit — the clause is, and the person who has read it is. Everything published cites its source so you can go and check, and where the honest answer is "read Annex II yourself, it's four paragraphs", that's the answer you'll get.

It also isn't advice — legal, regulatory or otherwise. Standards and legislation move, sometimes the week after something is published, and an archive is a snapshot of what was true when it was written. Check the source document and take proper advice before making decisions that matter.

The necessary bits

Written in a personal capacity. The views here are mine alone, not those of my employer, and nothing published draws on any employer's confidential or commercial information.