This page covers the EU traceability and lot-marking requirements applicable to algal food products sold in pre-packed form. Traceability obligations arise from several instruments and apply at different points in the supply chain; this page focuses on the obligations most directly relevant to algae producers and processors.

Regulation (EC) No 178/2002 of the European Parliament and of the Council of 28 January 2002 laying down the general principles and requirements of food law, establishing the European Food Safety Authority and laying down procedures in matters of food safety, OJ L 31, 1.2.2002, p. 1. EUR-Lex

Relevance to algae: Article 18 of the General Food Law establishes a general, horizontal traceability obligation that applies to all food businesses in the EU:

• One step back, one step forward: food businesses must be able to identify (a) the businesses from which they received any food, feed, food-producing animal or substance likely to be incorporated into food, and (b) the businesses to which their product has been supplied.
• Information on request: this information must be available to competent authorities on request.
• Labelling or identification: food placed on the market or likely to be placed on the market must be adequately labelled or identified to facilitate traceability.

This is not a requirement to maintain a full track-and-trace system at batch or unit level; it is a “one up, one down” traceability obligation. However, more specific traceability obligations (lot marking and others) are imposed by other instruments described below.

Council Directive 2011/91/EU of 13 December 2011 on indications or marks identifying the lot to which a foodstuff belongs (codification of Directive 89/396/EEC), OJ L 334, 16.12.2011, p. 1. EURlex

Relevance to algae: This Directive requires that pre-packed food products (and food not pre-packed when sold for mass catering or further processing) bear a lot mark — typically prefixed by the letter “L” — enabling the batch of production to be traced. The lot mark connects each individual pack to the batch production records held by the food business, enabling recall and traceability actions in the event of a safety issue.

The lot is defined by the producer and may correspond to a daily production batch, a processing run, or a specific raw material input batch. For algae producers, which may have significant batch-to-batch variability in product characteristics (composition, colour, iodine content), the lot system also has quality management value beyond its regulatory function.

Practical note: the lot mark may take the form of any code (alphanumeric, date-based) chosen by the producer; it does not need to be externally decoded. The requirement is that the information enabling decoding is held by the producer and available to competent authorities.

Regulation (EU) No 1379/2013 on the common organisation of the markets in fishery and aquaculture products (CMO Regulation), OJ L 354, 28.12.2013, p. 1. EUR-Lex

Relevance to algae: As covered in detail in Food Labelling, the CMO Regulation imposes specific traceability and consumer information requirements for algae and seaweed products sold as food in essentially unprocessed or minimally processed form. Beyond the labelling requirements, the CMO Regulation supports traceability through its requirements for lot/batch identification across the supply chain for fishery and aquaculture products. Producers of seaweed and algae products that fall within the CMO's Annex I product categories should be aware that their supply chain documentation requirements are supplemented by this Regulation.

Regulation (EU) 2017/625 of the European Parliament and of the Council of 15 March 2017 on official controls and other official activities performed to ensure the application of food and feed law, animal health and welfare rules, plant health and plant protection product rules, OJ L 95, 7.4.2017, p. 1. EUR-Lex

Relevance to algae: Official controls on food businesses — including inspections of production records, traceability documentation, and product testing — are carried out by national competent authorities under the framework established by this Regulation. Food businesses, including algae producers, must cooperate with official controls and must maintain traceability records in a form that enables efficient verification by inspectors.

In practice, this means that lot records, raw material intake records, and dispatch records should be maintained for a sufficient period (typically at least five years, by analogy with general bookkeeping obligations and the shelf life of the products) and be readily accessible.

For algae products imported from third countries, import conditions under Regulation (EU) 2017/625 include requirements for documentation establishing the traceability of the product back to its point of production. Import lots of certain algae-based products from non-EU countries may be subject to increased controls or sampling, particularly where the product has been subject to alerts in the Rapid Alert System for Food and Feed (RASFF). Importers should be aware that:

• A full traceability chain to the original harvest or production site in the third country is expected for products entering the EU food supply.
• RASFF alerts for contaminant levels in algal products (cyanotoxins, heavy metals, iodine) from specific origins can trigger increased inspection rates for shipments from those countries or producers.

• Implement a one-up, one-down records system as a minimum — know your raw material suppliers and your immediate customers, with records available to authorities on request.
• Apply a lot mark to every pre-packed product and maintain internal records enabling the lot to be traced back to the raw material batch.
• For seaweed and marine macroalgae sold as food in essentially unprocessed form, comply with CMO traceability and labelling requirements (country of cultivation, production method, species) in addition to the general food law traceability system.
• Retain records for at least five years as a prudent standard, longer where the product's shelf life warrants it.
• If importing from third countries, ensure your supplier can provide full traceability documentation back to production, as this is increasingly expected by EU importers and customs/food safety authorities.

See also: Food | Food Labelling | Food Packaging | Production, Processing and Hygiene — General | Aquaculture and Wild Harvesting

Last reviewed: June 2026.