In 2013, frozen beef products across Europe tested positive for undeclared horse meat. The products were labelled correctly, according to the paperwork. The supply chain behind the label was doing something else entirely. That’s the traceability problem in a single, well-known scandal, and food and hospitality brands are still living with a version of it today, just spread across more markets and more supply chains than one European recall could ever cover.
The pressure to fix it isn’t moving at the pace you’d expect, either. The FDA pushed the compliance deadline for its own food traceability rule, FSMA 204, back to July 2028 earlier this year. Read that as breathing room and you’d be missing the point: Walmart’s own supplier traceability requirements took effect in August 2025 and are already generating chargebacks for non-compliant shipments, more than two years ahead of the federal deadline. The retailer’s floor is stricter than the regulator’s ceiling. For an international food or restaurant brand, that’s exactly where the risk sits, in the gap between what head office promises and what’s actually enforced at the point of sale.
The traceability problem is bigger than the system
Traceability exists for a practical reason. If something goes wrong, a business needs to know where the affected food came from and where it went.
The same records can also sit behind the claims a brand makes about origin and sourcing.
That’s where the gap starts to matter. An approved-supplier system can show what a restaurant should be buying. It doesn’t tell you whether a local operator substituted a product when stock ran short, whether the origin on the menu was updated when that happened, or whether the records on site can actually support the claim being made to the customer.
The food may still be perfectly safe. The brand promise may still be wrong.
And if the traceability itself has broken down, the problem becomes more serious the moment there’s a recall and someone needs the records to work quickly.
Why this matters once you operate across markets
A central procurement dashboard can confirm a supplier holds Red Tractor or GlobalG.A.P. certification. It can’t confirm today’s delivery actually came from that supplier. An internal compliance return tells you whether a location says it is following the standard. Neither tells you exactly what’s sitting in a restaurant kitchen or on a retail shelf on a particular day.
Can the ingredient be traced backwards from the point of sale? Does the supplier on the invoice match the approved one? If a substitution was made, was it authorised? Does the provenance claim still hold? Can local staff explain it accurately?
Those are execution questions, not policy questions, and they only get answered by checking what’s actually happening on the ground.
What to check, market by market
- Can the product actually be traced backwards, starting with what’s being sold rather than with the approved-supplier list
- Do origin and sourcing claims match the records, including the farm, region, country or production method where those form part of the brand promise
- Are substitutions being controlled, particularly when shortages force local teams away from the usual supply route
- Do local teams understand the standard, or does the explanation given to a customer differ from the one written at head office
- Does the same test produce the same result across markets, so isolated failures can be separated from a wider problem in the system
The question isn’t whether the traceability policy works on paper. It’s whether you can start with the food in front of the customer and prove the story behind it.
ILLUSTRATIVE EXAMPLE
One sourcing policy, four different realities
An international restaurant group promotes the same farm-to-table sourcing policy across four markets. Approved-supplier records look consistent and every market reports compliance through the normal internal process.
An audit starts at the other end of the chain.
Menu items are selected in individual restaurants and key ingredients are traced backwards through local delivery records, purchasing documentation and approved suppliers. In two markets, the chain works as expected. In a third, a distributor has substituted an ingredient during a supply shortage but the provenance information at restaurant level hasn’t changed. In the fourth, the restaurants can identify the distributor but can’t produce enough evidence to support the specific origin claim appearing on the menu.
None of that appears in the central supplier list, because the central supplier list isn’t what was being tested.
The findings let the group separate a sourcing problem from a record-keeping problem, correct the affected claims and tighten the substitution process before a complaint, an audit or a food-safety incident tests the system for real.
This example is illustrative and anonymised. It reflects the kind of engagement we run, not a specific identifiable client.
Where this usually goes wrong
Brands assume a single sourcing standard produces a single reality everywhere it’s rolled out. It doesn’t.
Local shortages, substitutions, distributor practices and record-keeping all vary by market, and a central dashboard can miss every one of them. The only way to know whether the promise being made to the customer still holds is to check it directly.
