A supplier reports that a delivery may be faulty. The decisive question is then not “Who is to blame?” but: Which products contain this material, and where are those products now? Anyone who has batch traceability under control answers that in minutes and blocks precisely what is affected. Anyone who has not either blocks far too much as a precaution or keeps delivering without knowing it. This guide explains what batches are, what the law requires for food and consumer goods, and how to manage batches so that a recall can be prepared.
Terms and directions of traceability
A batch (also called a lot) is a quantity of goods that was produced or delivered under the same conditions and carries a common number. A serial number, by contrast, identifies a single item. Which level you need depends on the goods: flour and screws typically run by batch, machines and devices by serial number.
Traceability works in two directions:
- Backwards: What was this batch made from, and which supplier did the material come from?
- Forwards: Where did the batch go, which subsequent batches was it processed into, and which customers received it?
You need both directions. Backwards you find the cause, forwards you limit the consequences. The chain is only as strong as its weakest link: if an ingredient is mixed into a new batch without a batch number, the trail breaks.
What the law requires
We limit ourselves to three enactments that are relevant for many SMEs and that we have checked against the original text. For certain products, traceability is a statutory requirement in them.
Food and other products. Under Art. 28, para. 1 of the Foodstuffs Act (LMG), the following must be traceable at all levels of production, processing and distribution: foodstuffs, animals intended for food production and all substances that are intended to be, or may be expected to be, processed into a foodstuff, as well as consumer articles, cosmetics and toys. Companies must set up systems and procedures so that, at the authorities’ request, they can provide information on their suppliers and on the companies to which they have supplied their products (Art. 28, para. 2 LMG).
The Foodstuffs and Utility Articles Ordinance (LGV) specifies this in Art. 83. Anyone trading in such products must be able to tell the competent cantonal enforcement authority from whom they obtained them and to whom they supplied them. Direct supply to consumers is excluded (para. 2). For foodstuffs of animal origin, sprouts and seeds for the production of sprouts, additional information applies, including a reference identifying the lot, batch or consignment (para. 3). The information must be kept available at least until the product can be assumed to have been consumed (para. 4, for foodstuffs).
Anyone who neglects traceability risks a fine: whoever wilfully contravenes the traceability rules under Art. 28 is liable to a fine of up to CHF 40’000, and up to CHF 20’000 if acting through negligence (Art. 64, para. 1 lit. k and para. 4 LMG).
Withdrawal and recall. If the person responsible in a business discovers, or has reason to assume, that foodstuffs or utility articles supplied by the business have endangered or may endanger health, and they are no longer under the business’s direct control, Art. 84, para. 1 LGV requires them to inform the competent cantonal enforcement authority without delay, take the measures needed to withdraw the products and, if the products may already have reached consumers, recall them and give the reason.
Consumer goods. For consumer goods that are not covered by food law, the Product Safety Act (PrSG) applies (Art. 1, para. 3 PrSG). It obliges manufacturers and importers of products intended for consumers, or which under reasonably foreseeable conditions could also be used by them, to take appropriate measures in the course of their business, among other things so that the product can be traced (Art. 8, paras. 1 and 2 lit. c PrSG). If the manufacturer or another person placing the product on the market discovers, or has reason to assume, that their product poses a danger to safety or health, they must notify the competent enforcement body without delay, among other things of the details identifying the product and all available details of from whom they obtained it and, except in the case of direct supply to users, to whom they supplied it (Art. 8, para. 5 lit. a and c PrSG).
Special rules may apply to other sectors, such as medical devices or chemicals, which we have not checked here. Customer contracts also often require batch records. Whether and how far your business is affected, clarify with the competent enforcement authority or your trade association.
What ISO 9001 says
If your business works to ISO 9001, clause 8.5.2 (“Identification and traceability”) is the point of reference. In substance, it is about identifying outputs where this is necessary to ensure conformity and, where traceability is a requirement, controlling and retaining the unique identification. As we understand it, the clause does not prescribe a particular form: whether you keep the trail on paper, in a spreadsheet or in a system is up to you.
On the edition: The 6th edition, ISO 9001:2026, has applied since 16 September 2026 and replaces the 2015 edition. The clause number and the description of content above come from the 2015 edition and have not been checked against the text of the 2026 edition. According to a Swiss certification body, the changes overall are moderate, without a fundamental new direction. Check number and wording in your edition; certified companies switch within the transition period set by their certification body. This guide does not reproduce the text of the standard.
What to record per batch
For each batch you need a few reliable details:
- a unique batch number that is never assigned twice;
- the item and, where applicable, the best-before date;
- the supplier and the date of receipt, with quantity and unit;
- the usage: which subsequent batch the goods went into;
- the dispatch: which customers or which order the batch went to, with delivery note number and quantity;
- the status: released or blocked.
You should adopt the supplier’s batch number or map it unambiguously to your own. Record the link between ingredient and product at the time of production, not afterwards. Anyone who reconstructs the usage only after the event will reconstruct it wrongly when it matters.
Blocking and preparing a recall
As soon as there is a suspicion, the order of steps matters. First you block the affected batch and all subsequent batches made from it, so that nothing is shipped or processed further. Then you establish what has already been delivered: how much, to whom, with which delivery note. After that, the responsible person assesses whether there is a hazard, whether the authority has to be informed, and whether withdrawal, recall and information to customers are needed (for foodstuffs and utility articles Art. 84, para. 1 LGV; for other consumer goods a notification to the enforcement body under Art. 8, para. 5 PrSG). The block is an internal immediate action; notification and communication remain separate steps.
Rehearse the emergency once a year. Choose any batch and find out how long it takes you to name all subsequent batches and all recipients. This test is practice, not a statutory requirement, but it exposes the gaps before it counts.
Practical example: Muster Feinkost GmbH
Muster Feinkost GmbH is a fictitious company that fills basil oil into bottles. On 12.10.2026 the basil batch BAS-2610-07 arrives from Muster Kräuter AG: 40 kg. Two fillings are made from it, each with 50 g of basil per bottle:
- Filling P-2610-41 uses 22 kg and yields 22 ÷ 0.05 = 440 bottles.
- Filling P-2610-42 uses 18 kg and yields 18 ÷ 0.05 = 360 bottles.
Together that is 22 + 18 = 40 kg and 800 bottles. The deliveries were:
| Filling | Recipient | Bottles |
|---|---|---|
| P-2610-41 | Muster Feinkostladen | 200 |
| P-2610-41 | Muster Gastro AG | 120 |
| P-2610-42 | Muster Gastro AG | 100 |
| P-2610-42 | Muster Hofladen | 150 |
That is 200 + 120 + 100 + 150 = 570 bottles to three customers. The remaining 120 + 110 = 230 bottles are in stock (570 + 230 = 800).
On 22.10.2026 Muster Kräuter AG reports a quality problem with batch BAS-2610-07. Muster Feinkost GmbH looks up the batch, sees forwards the two fillings and the four deliveries, and blocks the basil batch together with the subsequent batches. That makes three batches blocked; if the fillings are managed in the Finance warehouse with the same batch numbers, the warehouse no longer allocates the 230 bottles. The responsible person then assesses whether a health hazard is possible and, where applicable, informs the cantonal enforcement authority and the three customers without delay. Muster Feinkost GmbH must be able to name the deliveries to the three customers to the authority. If the Hofladen sells the bottles directly to consumers, it does not have to record their names (Art. 83, para. 2 LGV); in the event of a recall, however, consumers must be told the reason (Art. 84, para. 1 lit. c LGV).
Checklist
- Check whether the LMG, LGV or PrSG apply to your products
- Unique batch numbers, never assigned twice
- Supplier batches recorded on goods receipt
- Usage in subsequent batches recorded at production
- Dispatch per batch recorded with recipient and delivery note
- Best-before date maintained where needed
- Blocking, including subsequent batches, possible at any time
- Responsibility for notifying authorities and informing customers settled
- Retention period for the records defined
- Traceability rehearsed at least once a year
How KMU | base helps
In QMS | base you find the batches in the menu under Operations and records › More › Batches. The page is visible to people with the right to edit records.
Batches with supplier. You record batches with item, supplier, date of receipt and quantity, and search them by number or item. The batch number is unique per client.
Traceability forwards and backwards. You record the usage in subsequent batches and the dispatch to recipients, with reference (delivery note, order) and quantity. On the batch page you see the chain in both directions: forwards the subsequent batches and dispatches, backwards the source batches.
Batch block with subsequent batches. You block a batch and, if you wish, all subsequent batches to prepare a recall, and release them again later.
Batches from the Finance warehouse. Goods receipts and deliveries with a batch from Finance | base appear in traceability without double entry. In Finance | base, you switch on traceability for the item (batch or serial number, with a mandatory best-before date if you wish); withdrawals follow the shortest best-before date. The warehouse no longer allocates batches blocked in QMS. QMS | base matches the supplier by name if it corresponds to a supplier in QMS | base (upper and lower case do not matter).
What the software does not do: You record the usage of a batch in a subsequent batch by hand in QMS | base; goods receipts and deliveries are taken over from Finance | base. The block works forwards, that is, on subsequent batches; source batches are not blocked as well. It blocks in the warehouse, but it informs neither customers nor authorities and does not replace a recall; those steps remain your task. Taking over from the warehouse and blocking in the warehouse require that Finance | base is booked.
The guide to QMS | base explains how to use it. For the warehouse in Finance | base, the guide Stocktaking in the warehouse gives background. Take a look at the demo or open a trial account. If you have questions, the contact page will help.
Sources
- Federal Act on Foodstuffs and Utility Articles (Foodstuffs Act, LMG, SR 817.0), Art. 28, paras. 1 and 2 and Art. 64, para. 1 lit. k and para. 4, as at 1 October 2024: fedlex.admin.ch (German original), accessed on 27.10.2026.
- Foodstuffs and Utility Articles Ordinance (LGV, SR 817.02), Art. 83, paras. 1 to 4 and Art. 84, para. 1, as at 1 July 2025: fedlex.admin.ch (German original), accessed on 27.10.2026.
- Federal Act on Product Safety (Product Safety Act, PrSG, SR 930.11), Art. 8, paras. 1, 2 and 5, as at 1 September 2023: fedlex.admin.ch (German original), accessed on 27.10.2026.
- SNV: SN EN ISO 9001:2026, Quality management systems – Requirements, valid since 16 September 2026, replaces the 2015 edition; accessed on 27.10.2026. The clause reference 8.5.2 comes from the 2015 edition and has not been checked against the 2026 text.
- ISO: ISO 9001:2026 (Edition 6), published on 16 September 2026; accessed on 27.10.2026.
- SQS: ISO 9001:2026 revision of the standard – all information, accessed on 27.10.2026.
The procedure, example figures and rehearsal recommendation are editorial practical aids. They do not reproduce ISO standard text and do not demonstrate conformity for certification.
This guide does not replace legal or tax advice. Information as at 27 October 2026.