Lot, batch and expiry control in an EU warehouse
FEFO or FIFO, batch records and traceability: which EU rules call for lot control for food, cosmetics, consumer products and medical devices, and why.
Lot control means the warehouse knows, for every unit it holds and ships, which production batch it came from and, where relevant, when it expires. Several EU laws make batch identification a legal requirement for the product: food under Regulation (EC) No 178/2002, cosmetics under Regulation (EC) No 1223/2009, consumer products under the GPSR, and medical devices under the MDR’s UDI system. The warehouse is where that identification either survives the journey to the customer or gets lost.
The legal duties sit with the manufacturer, the importer or the distributor. The warehouse’s systems decide whether those parties can actually meet them.
What is the difference between FEFO and FIFO?
FIFO, first in, first out, picks the stock that arrived earliest. FEFO, first expired, first out, picks the stock that expires earliest, whatever its arrival date.
The two give the same answer only when every delivery has a later expiry date than the one before. That breaks easily. Two production runs can arrive in the same container, or a later delivery can come from an older run. For any product with a shelf life, FEFO is the rule that protects the date, because it reads the date rather than the arrival order.
FEFO also needs a policy for what happens near the end. A warehouse can hold back stock that has less than an agreed remaining shelf life, because some buyers will not accept it. That threshold is a commercial decision, set per product and per channel.
Which EU rules require batch or lot traceability?
Each regime asks for something slightly different.
| Product | Rule | What it asks |
|---|---|---|
| Food and feed | Regulation (EC) No 178/2002, Article 18 | Operators identify who supplied them and which businesses they supplied, and give that to authorities on demand |
| Cosmetics | Regulation (EC) No 1223/2009, Article 19(1)(e) and (c) | Batch number or reference on the label; date of minimum durability, or period after opening where durability exceeds 30 months |
| Cosmetics, distributors | Regulation (EC) No 1223/2009, Article 6(2) | Before supply, distributors check that the minimum durability date, where required, has not passed |
| Consumer products | Regulation (EU) 2023/988 (GPSR), Article 9 | Manufacturers make the product identifiable, including a batch or serial number or other identifying element |
| Medical devices | Regulation (EU) 2017/745 (MDR), Article 27 | UDI with a device identifier and a production identifier; UDI storage for class III implantable devices |
Article 18 of the food regulation is often summarised as “one step back, one step forward”. A business must be able to name its immediate supplier and its immediate business customer. It does not require tracing to the consumer.
The cosmetics rule on distributors is the most direct for a warehouse. A distributor may not supply a cosmetic whose minimum durability date has passed, so the date has to be known at the moment of picking.
Does a warehouse need to record batch numbers on outbound orders?
The law rarely says “the warehouse” in so many words. It places the duty on the economic operator: the food business, the cosmetics distributor, the device importer. In practice, that operator can only answer an authority, or run a recall, if the warehouse recorded the batch at two points.
- On receipt. Each batch arriving is booked separately, with its expiry date where the product has one.
- On dispatch. Each order line records which batch left, to which customer, on which date.
Without the second record, the operator knows what it bought but not where it went. For a business customer, that breaks the “one step forward” link. For a consumer product, it means a recall has to be addressed to every buyer instead of the few who received the affected batch.
How does a UDI differ from a batch number?
A batch number identifies a production run. The UDI under the MDR identifies the device and, through its production part, the unit of production.
Article 27 splits the UDI in two. The UDI device identifier, or UDI-DI, is specific to a manufacturer and a device model. The UDI production identifier, or UDI-PI, identifies the unit of device production and, if applicable, the packaged devices. The UDI-PI is where lot or serial number and dates sit.
For class III implantable devices, Article 27(8) adds a storage duty. Economic operators store and keep, preferably by electronic means, the UDI of the devices they have supplied or been supplied with. Health institutions have the same duty under Article 27(9). A warehouse serving those flows needs to capture the full UDI, not only a lot code, at receipt and dispatch. Storing and shipping medical devices in the EU covers the rest of the device rules.
A worked example
Suppose a skincare brand from outside the EU holds a face serum in Portugal. All figures are hypothetical, for the mechanics only. Batch A, 3,000 units, arrived in March with a minimum durability date two years out. Batch B, 2,000 units, arrived in May from an older run, and expires eight months sooner.
Under FIFO, batch A ships first and batch B sits behind it, losing shelf life every week. Under FEFO, batch B ships first, because its date is closer. The brand’s rule for the retail channel is that no unit ships with less than twelve months of life left, so the warehouse blocks any batch B stock that crosses that line and reports it.
In November, the brand’s safety assessor flags a problem with batch A only. Because each order line carries its batch, the brand can list exactly which retailers and which consumers received batch A, and which did not. The next step is a recall, not a guess.
Why does lot control matter in a recall?
Safety Gate, the EU’s rapid alert system for dangerous non-food products, recorded 4,671 alerts in 2025, the highest number since it began in 2003. A recall under the GPSR has to reach affected consumers directly where their contact details are known. Batch-level records decide how many consumers are “affected”.
With batch data, a recall is narrow: one batch, a known list of orders, a quarantine on the remaining units. Without it, the only safe notice covers every unit ever sold. The difference is set out in product recalls in the EU: Safety Gate and GPSR.
What should be agreed with the warehouse before the first delivery?
- Which products are batch-managed, and whether the batch number appears on the carton, the unit or both.
- Which products carry an expiry date, and the picking rule: FEFO, with any minimum remaining shelf life per channel.
- Whether serial numbers or full UDIs must be captured, and at what level of packaging.
- What happens to expired, damaged or quarantined stock, and who decides.
- The format and speed of a batch-to-order report when the brand asks for one.
This is general information, not legal advice. Which traceability rules apply to a given product is confirmed with the manufacturer and its regulatory advisers.
How this runs at EFC
Traceability duties stay with the brand and its importer or distributor. That is why batch, expiry and picking rules are among the points settled with each client before stock arrives at EFC’s base in Portugal, run with its logistics partner. Medtech and beauty brands selling in Europe hold stock there today, as described on warehousing. For consumer products, EFC acts as GPSR Responsible Person, set out on responsible person. It is neither the cosmetics Responsible Person nor an EU Authorised Representative for medical devices.
Sources
| Label | Value | Source |
|---|---|---|
| Food traceability | identify suppliers and business customers; information to authorities on demand | Regulation (EC) No 178/2002, Article 18, on legislation.gov.uk, opened 2026-07-28 |
| Cosmetics labelling | batch number or reference; minimum durability date, or period after opening beyond 30 months | Regulation (EC) No 1223/2009, Article 19, EU text on legislation.gov.uk, opened 2026-07-28 |
| Cosmetics distributors | check minimum durability date has not passed before supply | Regulation (EC) No 1223/2009, Article 6, EU text on legislation.gov.uk, opened 2026-07-28 |
| GPSR identification | batch or serial number or other identifying element; applies from 13 December 2024 | GOV.UK, EU Regulation 2023/988 on general product safety, detailed guidance, opened 2026-07-28 |
| UDI | UDI-DI and UDI-PI; storage for class III implantable devices by economic operators and health institutions | Regulation (EU) 2017/745, Article 27, EU text on legislation.gov.uk, opened 2026-07-28 |
| Safety Gate 2025 | 4,671 alerts, highest since 2003 | European Commission, press release IP/26/537, 5 March 2026, opened 2026-07-28 |