General Food Regulations 2004
General food safety and traceability requirements
The General Food Regulations 2004 (SI 2004/3279) implement Regulation (EC) No 178/2002 (the General Food Law Regulation) in England. This EU regulation established the European Food Safety Authority and set out the general principles and requirements of food law, including the precautionary principle, traceability requirements, and responsibilities for food business operators. Under these regulations, food business operators must ensure that food is safe and must be able to identify who supplied them with any food, ingredient, or food-producing animal, and who they have supplied in turn. This "one step back, one step forward" traceability is a fundamental requirement. The regulations also set out the obligations to withdraw or recall food that does not comply with food safety requirements.
Key Requirements
Traceability (one step back, one step forward)
Food business operators must be able to identify who supplied them with food or ingredients, and (where applicable) to whom they have supplied food. Records must be available to competent authorities on demand.
General food safety requirement
Food shall not be placed on the market if it is unsafe. Food is considered unsafe if it is injurious to health or unfit for human consumption.
Withdrawal and recall obligations
If a food business operator has reason to believe that food they have imported, produced, processed, or distributed does not comply with food safety requirements, they must immediately initiate withdrawal from the market and inform the competent authorities.
Presentation must not mislead
The labelling, advertising, and presentation of food shall not mislead consumers about the nature, identity, properties, composition, or other characteristics of the food.
What Your Business Must Do
Maintain supplier records
Keep records of all food suppliers including delivery notes, invoices, and specifications. You must be able to identify who supplied any food product or ingredient.
Keep customer supply records where applicable
If you supply food to other businesses, maintain records of who you supply and what you supply to them.
Establish a withdrawal and recall procedure
Have a documented procedure for withdrawing unsafe food from sale and, if necessary, recalling food from consumers. Know how to contact the FSA.
Check food safety at receipt
Inspect deliveries for damage, temperature compliance, and date marking. Reject any food that does not meet safety requirements.
Penalties for Non-Compliance
Placing unsafe food on the market
Up to 2 years imprisonment and/or an unlimited fine on conviction on indictment. Up to 6 months and/or an unlimited fine on summary conviction.
Failure to maintain traceability records
An unlimited fine on summary conviction. The inability to trace food through the supply chain is treated as a serious compliance failure.
Failure to withdraw or recall unsafe food
Up to 2 years imprisonment and/or an unlimited fine. Operators must act immediately on discovering food does not meet safety requirements.
How Paddl Helps
Supplier management
Maintain digital supplier records with contact details, delivery schedules, and product specifications for full traceability.
Delivery checks via routines
Set up delivery check routines to ensure food is inspected on receipt for temperature, condition, and date marking.
Document storage
Store supplier certificates, specifications, and compliance documents digitally for instant access during audits or inspections.
Frequently Asked Questions
What does one step back, one step forward mean?
It means you must be able to identify who supplied you with any food or ingredient (one step back) and who you have supplied food to (one step forward). You do not need to trace the entire supply chain, just the immediate links.
How long must I keep traceability records?
There is no specific retention period stated in the regulation for catering businesses. However, best practice is to keep records for at least the shelf life of the product plus a reasonable period afterwards. For non-perishable items, 5 years is commonly recommended.
Do these regulations apply after Brexit?
Yes. Regulation (EC) 178/2002 was retained in UK domestic law. The Food Standards Agency continues to be the competent authority, and all requirements including traceability continue to apply.
Stay compliant with GFR 2004
Paddl makes regulatory compliance simple. Digital records, automated reminders, and audit-ready documentation — all in one platform built for UK hospitality.