关键要点
- Retain records for the longest applicable regulatory period.
- Records must be retrievable, not merely stored.
- Link documents to the lot, not to the supplier folder alone.
What to retain per lot
Purchase order and specification version, contract, invoice and packing list, transport document, certificates, inspection and sampling records, your own analytical results, goods receipt, deviation records and correspondence relating to any claim.
Retrievability
A retention policy is only effective if a named lot's full file can be produced quickly. Indexing by lot number rather than by supplier or date is what makes traceability exercises and recall investigations feasible.
Electronic records
Where records are electronic, ensure integrity controls, backup and readability over the retention period. Formats and systems change faster than retention periods run.
需要核查的内容
- Written retention policy referencing applicable regulatory periods
- Lot-indexed retrieval tested by exercise
- Backup and readability of electronic records confirmed
需管理的风险
- Unable to evidence due diligence during an official inspection
- Records held but not retrievable within a useful timeframe
- Electronic records unreadable after a system change
常见错误
- Filing by supplier only, with no lot index
- Deleting records at the end of a commercial relationship
- Assuming the freight forwarder retains copies on your behalf
常见问题
How long should records be kept?
For the longest applicable period among feed law, customs law and contractual limitation periods in the relevant jurisdictions.
Are scanned copies acceptable?
Usually yes for most purposes, though certain customs and official documents may require originals. Confirm per document type rather than applying one rule.