Labeling, Coding, and Traceability
Requirements Revision: 17-Feb-2023
Purpose
To ensure materials, intermediates, and finished beverages are uniquely identified to determine
status and to enable two-way traceability, as well as provide requirements for coding, labeling,
and relabeling products.
Scope
This document applies to all operations manufacturing and/or distributing for or on behalf of The
Coca-Cola Company.
Labelling
1 All labels must be stored in a controlled area to prevent unauthorized use. Storage
conditions (e.g., temperature, humidity, etc.) should be in accordance with supplier
recommendations.
2 Develop and implement programs for product labelling. The program must contain, at a
minimum:
• Ensuring all labels used by the manufacturing plant are approved for use by the
Operating Unit for the specific product/package configuration.
• Outline the process for verification of all labels at start-up and during production (i.e.,
correct label goes on the right package, information is legible). Includes actions to be
taken at product changeover
• Process for storing and allocation of labels that prevents mixing of different product
labels, or campaigns within the same product type.
• Method for identification of label status (e.g., approved/rejected) including process for
the segregation of non-conforming material together with process to identify and store
these materials that prevent their use.
NOTE: When the correct labelling of the allergenic ingredients, and precautionary
warning, is the only way to control the significant allergen hazard, the label approval step
could be considered as Critical Control Point (CCP) at OU level. Other CCPs may also
need to be defined, relating to receipt of packaging materials or usage of correct
materials in the factory. This may vary depending on the products made in the factories,
level of complexity being managed, and procedures applied to manage packaging
changes. However, CCP/CCPs selected should ensure that all stages of this process
are fully under control.
2.1 Employees must be trained and understand the importance of correct receipt, storage,
inspection, and disposition of the labels.
3 When barcode scanners or vision systems are available, challenge tests must be performed
and recorded for each production.
3.1 Barcode scanners and vision systems must be validated for each product and before
every time a new label is used for the first time.
3.2 Implement and maintain a preventive maintenance and calibration program based on
the manufacturer’s requirement.
QFS-RQ-090 Page 1 of 5 Revision: 17-Feb-2023
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Labeling, Coding, and Traceability
Requirements Revision: 17-Feb-2023
Relabelling
Process of changing an existing label on a product without repacking the product.
4 Notify OU and obtain approval when relabeling product.
4.1 Re-labeled products must be within their shelf-life and durability period.
4.2 Document and maintain records of a business justification to relabel.
5 Over-labeling (applying a label over another label, without repacking the product) is not
permitted.
6 Ensure two-way traceability and the original date of manufacturing is maintained for
relabeled product.
7 Identify and address the root cause to eliminate the need for relabeling.
Coding
All products are required to be labeled with either a date code or durability* code that allows for
both the effective traceability of products and for the consumer to identify optimum shelf-life* for
beverage consumption.
8 Develop and implement procedures for the coding of finished products. This should include
but not be limited to the following:
8.1 Coding requirements must comply with both Operation Unit and regulatory
requirements.
8.2 Primary container coding must be legible and comply with coding requirements.
8.3 For all products including repackaged and reconfigured products, calculate coding
from the original date of packaging/filling.
8.4 Secondary packaging must also be coded when the date code on the primary
packaging is not visible (e.g. cardboard carton, fridgepacks etc).
8.4.1 Shrink film or other similar secondary packaging materials used to hold
together individual units of product does not need to be coded as long as it can
be demonstrated that the date code remains visible on primary packaging. Any
obstruction to the visibility of the date code on the primary package will require
the secondary packaging to be coded.
8.4.2 When repackaged product contains multiple primary package date codes, then
ensure the code on any secondary packaging (that is required to be coded)
uses the earliest production date or the shortest durability period.
8.5 Confirmation that imported and exported products have product codes that meet
applicable regulations in country of sale.
8.6 Codes that enable product rotation and traceability, and
8.7 When using durability labeling, the use of “Best Before,” or similar text as part of the
code.
9 Codes must include at a minimum:
9.1 The ability to identify the manufacturing plant/line that produced the product.
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Labeling, Coding, and Traceability
Requirements Revision: 17-Feb-2023
9.2 Production date, durability period, or best before date (BBD).
9.3 The production time or sequence number.
10 All coding elements must be completely readable. If one of the coding elements are not
readable, stop the line and do not proceed with production.
10.1 Codes must be readable during the entire product shelf life.
10.2 The date code must be applied in such a manner as not to cover any of the
Trademarks, ingredient declarations or address details printed on the closure, label, or
secondary packaging.
10.3 The date code must be applied in such a manner as to be easily readable by
customers and consumers.
11 Implement and maintain a process to ensure product codes are correct at start-up and
maintained during the entire run and following process deviations such as line breakdown,
intervention on coding equipment, packaging change, etc.
12 Implement and maintain a preventive maintenance program for coding equipment based on
the manufacturer’s requirement.
Traceability
13 Develop and maintain a traceability system that ensures:
13.1 Products failing to meet required quality and food safety standards can be identified,
located, and removed from all necessary points of the supply chain.
13.2 Each location (manufacturing plant, warehouses, distribution centers, authorized
suppliers) has the ability to identify and locate 100% of stock within 24 hours (or less
where required to meet customer requirements) and can demonstrate two-way
traceability (backward and forward) in the supply chain.
Note: Operations supplying McDonald’s must demonstrate the ability to identify and
locate all products within three hours.
13.3 Identification of product lots/batches and their relation to lots/batches of incoming
materials (i.e., ingredients, packaging, processing aids, auxiliary materials in contact
with product).
13.4 Chaining batches must be recorded during the process to ensure traceability.
Chaining batches is when one batch of syrup, carbon dioxide, juice, liquid milk, or
beverage is added to another continuously without completely draining the tank and
creating a clear break between lots/batches.
13.4.1 Records must include at minimum:
• Date and time of chaining batches processes.
• Lots/batches involved in the chaining batches and their analysis data.
13.5 Linkage of production lots/batches to processing and delivery records through
distribution.
13.5.1 Traceability records containing the product lot/batches, when full pallets are
opened for picking or portions smaller than one pallet are distributed.
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Labeling, Coding, and Traceability
Requirements Revision: 17-Feb-2023
13.6 Traceability records retained according to the applicable local regulations and the
shelf-life of the finished product.
13.7 Record both the lot and sequence number for concentrate and beverage base
containers for traceability purposes.
Mock Traceability Exercise
14 Conduct mock traceability exercise twice per year for effectiveness and continuous
improvement. The lot chosen for traceability exercise must have part of the lot already
delivered to market to verify the manufacturing plant capability to trace one-step-forward.
14.1 If Global Audit Organization (GAO) challenges the traceability system in a given year,
this may be used as one of these assessments.
15 For operations supplying McDonald’s, conduct at least two mock traceability exercises per
year and demonstrate ability to identify and locate all products within 3 hours for the traced
product (e.g., Bag-In Box, mineral water, etc.).
15.1 If the manufacturing plant produces Bag-in-Box supplied to McDonald's, a Bag-in-Box
product must be chosen for the mock traceability exercise.
Note: The requirements for McDonald’s are in addition to the requirements to conduct
the mock traceability exercise unless the manufacturing plant only produces for
McDonald’s.
16 The mock traceability exercise must contain backward and forward product traceability.
16.1 Backward traceability must demonstrate available of information related to each lot or
batch of incoming material used (including ingredients, packaging, processing aids,
auxiliary materials in contact with product), process information and results.
16.1.1 Backward traceability must allow for 100% traceability of incoming materials
used during production (ingredients, packaging, processing aids, auxiliary
materials in contact with product). Includes information such as COAs and
COCs, receipt and release testing checks)
16.2 Forward traceability must be conducted at least one step up (e.g., distribution centers
or point of sale in case of direct supply).
16.2.1 A rationale containing the stock dates and quantities used for forward
traceability must be developed in cases where more than 100% products were
traced.
16.3 If the mock traceability exercise identifies exceptions to expected compliance,
implement corrective actions, and repeat the exercise to verify the effectiveness of the
actions taken.
Definitions
Coding: A unique identifier that is a combination of date code, production facility code and SKU.
Mock traceability: An exercise to test the ability of the system to track and trace finished
product from the manufacturing plant to a customer outlet.
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Labeling, Coding, and Traceability
Requirements Revision: 17-Feb-2023
Traceability: The ability to link specific lot codes from ingredients and packaging materials to a
specific manufacturing lot code (date code, production facility code and SKU), and trace the
product from manufacture through distribution to the customer outlet.
Shelf Life: The maximum age of a product/package at which it can maintain its designed quality
and food safety attributes under specific storage conditions and therefore may be sold to
consumers or used by customers of the Company. After the ‘shelf life’ date a beverage is
deemed unsafe and cannot be sold.
Durability or ‘best before’ date: the date until which a foodstuff retains its specific properties
such as taste, aroma, appearance, any specific qualities which relate to the product, vitamin
content etc. when the product has been stored appropriately and the package unopened. Many
beverages that are past their ‘best before’ date may be safe to drink, but their quality may have
deteriorated.
Additional Resources
Customer and Consumer Engagement and Response PRP-RQ-070
Food Allergen Management and Control QFS-RQ-760
Revision History
Revision Date Summary of Change
17-Feb-2023 Aligned with the QFS-RQ-760 Food Allergen Management and
Control requirement. Added note contemplating correct labeling of the
allergenic ingredients, and precautionary warning, as possible critical
control point in cases where this is the only way to control the
significant allergen hazard.
16-Jan-2023 Clarified that secondary packaging must also be coded when the date
code on primary packaging is not visible.
1-Mar-2022 Published as a result of the KORE 3.0 QSE Governance project.
Requirements revised and formatted to minimize duplication,
redundancy, and inconsistencies, ensuring clarity of expectations
while maintaining fit-for-purpose governance.
QFS-RQ-090 Page 5 of 5 Revision: 17-Feb-2023
Property of The Coca-Cola Company
Classified - Confidential