Auditing Chain of Custody compliance at retail and restaurant chains

What the requirement is, and why it exists

Under the GLOBALG.A.P. Chain of Custody version 6.1 standard, Part II defines compliance criteria for retail stores, wholesale outlets, distribution centers, and restaurant operators. Part II applies to retail stores and restaurant sites selling or displaying loose products featuring GGN label visual elements. The primary objective is ensuring certified products remain traceable, segregated, and correctly identified at the point of sale.

The standard establishes a clear distinction regarding certification scope. Outlets selling exclusively tamperproof packed consumer items featuring GGN label visual elements, GGNs, or CoC Numbers do not require an external certification body audit. However, if retail stores or restaurant outlets pack, repack, or label loose products with GGN label visual elements on-site, full CoC certification is required.

Compliance leads, quality managers, and internal auditors must understand the dual-level management structure required by Part II. Control Point CoC-RSRC 1.1 through Control Point CoC-RSRC 1.10 govern central office authority, while Control Point CoC-RSRC 2.1 through Control Point CoC-RSRC 7.2 apply to individual store sites. Establishing central governance alongside store-level execution prevents mislabeling and eliminates non-certified product substitution.

Dual-level management structure and input verification

Implementing Part II requires dividing compliance responsibilities between the central corporate office and individual retail or restaurant outlets. Control Point CoC-RSRC 1.1 mandates that the central office demonstrate legal ownership over all participating store sites and maintain an updated site register. The central office must assign a central authority to manage CoC conformance, oversee staff training, and execute an annual self-assessment covering all registered sites under Control Point CoC-RSRC 1.3.

Direct supplier authentication is enforced at corporate and site levels. Control Point CoC-RSRC 1.6 mandates that the central office establish a written procedure to systematically authenticate direct suppliers' GGNs or CoC Numbers in GLOBALG.A.P. IT systems before taking ownership. This digital check verifies certificate expiration dates and registered destination countries.

When goods arrive at store counters or distribution centers, staff must execute physical receipt checks. Incoming goods inspectors follow a four-step verification sequence upon delivery:

• Examine incoming delivery notes to verify that the supplier CoC Number or GGN is explicitly printed alongside the product description under Control Point CoC-RSRC 3.1.
• Cross-check physical delivery quantities against purchase orders and record calendar dates and responsible staff names in an incoming verification log.
• Apply delivery discrepancy protocols under Control Point CoC-RSRC 3.2 if products ordered as certified arrive without supplier GGNs or CoC Numbers on delivery notes.
• Immediately relabel and handle unverified shipments as non-certified products until the supplier provides documented corrective evidence restoring certified status.

Mass balance calculations and traceability method selection

Mass balance accounting is mandatory at central office and store levels under Control Point CoC-RSRC 1.4 and Control Point CoC-RSRC 2.3. The mass balance exercise proves that the volume of product sold or displayed with a certified claim does not exceed certified input quantities received minus operational losses.

Store-level mass balance calculations must account for intermediate processing and physical waste. Managers must record and reconcile physical inventory movements across three core operational parameters:

• Input and output parameters: Documentation must summarize incoming certified volumes, stored quantities, sales volumes, and physical conversion losses.
• Loss factor integration: Calculations must incorporate waste, shrinkage, display trimming, customer handling damage, and rejected items.
• Self-service loss allowance: In self-service retail environments, management must define an acceptable loss threshold to account for customer scanning mistakes.

Traceability execution is governed by Control Point CoC-RSRC 4.1, which offers two distinct pathways for bulk retail consumer items. Outlets may use the segregation method, allowing physical mixing of certified products from multiple certified suppliers if linked via batch numbers. Alternatively, outlets may use the identity preservation method, which prohibits physical mixing and preserves traceability back to a single producer GGN. Under Control Point CoC-RSRC 4.2, the traceable batch at store level is defined as the minimum batch volume specified in the site recall procedure.

Example

During an annual CoC Part II audit of a seafood restaurant chain, the auditor inspected the fresh fish display counter featuring bulk salmon displayed with GGN label signage. While the central office maintained IT supplier verification logs, the restaurant counter lacked a list of certified suppliers and counter staff could not answer basic questions regarding the GGN label. The auditor raised two Major Must non-conformances under Control Point CoC-RSRC 6.1 and Control Point CoC-RSRC 7.2.

To resolve the non-conformances, the restaurant chain installed counter display tags listing supplier CoC Numbers and delivered written FAQ training to service staff. In addition, management updated the central self-assessment log and verified store-level mass balance sheets.

Before your audit

• Verify that the central office maintains legal entity documentation and an updated register of all retail or restaurant sites.
• Confirm that central office and store-level annual self-assessments covering all registered sites are completed within the past twelve months.
• Audit IT system verification logs to confirm that all direct supplier GGNs and CoC Numbers are authenticated prior to purchase.
• Ensure store and distribution center mass balance calculations accurately incorporate sales, storage, physical waste, and shrinkage.
• Check that incoming goods delivery notes explicitly state supplier CoC Numbers or GGNs for all certified shipments.
• Verify that loose or bulk product displays at retail counters feature GGN label visual elements and accurate certified supplier lists.
• Distribute written FAQ sheets to counter staff and conduct mock interviews to confirm staff awareness of GGN label principles.
• Test the product recall procedure annually and verify that emergency contact lists for suppliers, certification bodies, and clients are current.

Questions people ask

Do retail stores selling only pre-packed GGN labeled products need a CoC audit?

No. Wholesale and retail stores or restaurant chain sites that sell exclusively tamperproof packed products bearing GGN label visual elements, GGNs, or CoC Numbers do not require a CoC audit or certification. Certification is required only if stores handle, pack, or label loose bulk products with GGN label visual elements, or if distribution centers trade outside the retail network.

What information must appear on delivery notes for direct-to-store shipments?

Control Point CoC-RSRC 1.8, Control Point CoC-RSRC 2.6, and Control Point CoC-RSRC 3.2 require suppliers delivering directly to stores to print their GGN or CoC Number on delivery notes and sales invoices. If a shipment arrives without these numbers, store staff must immediately consider the product non-certified and handle it as non-certified.

How is a traceable batch defined at the retail store or restaurant level?

Under Control Point CoC-RSRC 4.2, the traceable batch at store or restaurant level is defined as the minimum quantity that the company is willing to retrieve in case of a product recall. This batch definition must align with the batch parameters documented in the site's annual recall procedure.

What evidence must be provided to counter staff for consumer communication?

Control Point CoC-RSRC 7.2 requires management to provide written instructions, such as FAQ documents, to staff working at counters displaying GGN label visual elements. Staff must be trained to answer consumer queries about the GGN label, and auditors verify compliance through direct interviews.

Reference documents

• GLOBALG.A.P. Chain of Custody – control points and compliance criteria, v6.1_Nov22, Part II: Section CoC-RSRC 1, Section CoC-RSRC 2, Section CoC-RSRC 3, Section CoC-RSRC 4, Section CoC-RSRC 5, Section CoC-RSRC 6, Section CoC-RSRC 7
• GLOBALG.A.P. Chain of Custody – general regulations, v6.1_Nov22, Section 4.4.2, Section 5.5