Batch records that satisfy an inspector: traceability for small makers

A batch record you wrote for yourself and a batch record that holds up to an inspector are usually the same document — the difference is whether every number in it actually connects to another number somewhere else.

What "traceability" means in EU law

For cosmetics, Article 7 of Regulation (EC) No 1223/2009 requires you to be able to identify, on request, who supplied you with a given batch of ingredient or product and who you in turn supplied, for three years after that batch was made available. Article 19 requires the batch number itself to appear on the product's packaging — that printed number is the physical link between the shelf and your paperwork.

For soap, candles and other non-cosmetic goods, the General Product Safety Regulation ((EU) 2023/988) sets a parallel expectation: manufacturers keep documentation that lets a product be identified and, where relevant, lets the supply chain be traced, and make it available to a market surveillance authority on request. The exact wording differs from the cosmetics rule, but the shape is the same: a number on the product, a record behind the number.

What an inspector actually asks for

• The batch number printed on the product in front of them.
• Your record for that number: which recipe and version, the date it was made, and who made it.
• The ingredient lots that went into it, and which supplier each came from.
• The quantities actually used and the yield that came out.
• For a cosmetic, this same information is expected to sit behind the "method of manufacture" section of your Product Information File — the batch record isn't a separate universe from the PIF, it's the evidence the PIF's manufacturing statement rests on.

The single point of failure

Every traceability system fails at the same spot: a number that doesn't lead anywhere. The common ways it happens are mundane — restocking a shelf with a relabelled product and forgetting to give it a new batch number, decanting a supplier's ingredient into a smaller container without carrying the lot number across, or a handwritten page that's illegible or has gone missing by the time anyone asks. None of these are dramatic failures. They're just gaps, and a gap is exactly what an inspector, or a supplier's recall notice, will find.

A minimal record that actually holds up

• Date and batch ID — a date-plus-counter scheme is enough; the ID just needs to be unique and to be the one printed on the label.
• Recipe and version — which formulation, not just which product name.
• Ingredient lots and suppliers — every input, matched to the lot number on its own packaging or invoice.
• Actual quantities used and yield — what the scale said, and what came out the other end.
• Who made it and any deviation — a substitution, a longer cure, anything that wasn't in the recipe as written.

This is a general map, not legal advice, and requirements can differ if you sell through a retailer with its own documentation demands or outside the EU. Check the current text of Regulation (EC) No 1223/2009 and Regulation (EU) 2023/988 on EUR-Lex for the exact obligations that apply to what you make.