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Supplier evidence / Implementation guide

Material origin and chain of custody

Trace material production and transformations alongside custody handovers, keeping upstream origin distinct from shipping location.

Published 4 October 2026 · Independent editorial guidance

Origin and movement answer different questions

A shipping record can show where goods were dispatched. Material origin concerns where an input was extracted, grown or produced and how it became part of the product. A product can travel through several countries without those locations describing the origin of each material.

Keep the operational material history separate from any legal customs-origin determination. That determination uses its own applicable rules. For traceability, retain the upstream sites and transformations even if the final product has a different customs origin or export location.

Connect inputs to outputs

Record which lots entered a production run, the output lots created and the facility performing the work. Capture the quantity basis, units and relevant timing. Explain losses, yields, split lots and merged batches well enough for a reviewer to understand the relationship.

When a lot is relabelled or repacked, preserve the earlier identifier. An internal code should be a bridge to the supplier record rather than the point at which history disappears. The product genealogy guide explains these input-to-output relationships.

Record custody without overstating what it proves

Custody records identify who held or transferred the material and when. Connect dispatches with receipts using lot, shipment and facility references. Record discrepancies in quantity or condition and preserve how they were resolved.

Ownership and custody may differ. A logistics provider can hold goods without owning them. A custody trail helps reconstruct movement, but it does not independently establish labour conditions at an upstream production site. Keep that evidence linked as a separate layer.

Make mixing and allocation visible

If inputs are pooled, ask which physical lots could contribute to the output and what the records can establish. A bookkeeping allocation is not automatically proof that a particular physical input was segregated from another. Describe the method and its limits rather than presenting every claim as a batch-specific physical trace.

In a fictional example, two input lots enter one processing run. The output record should preserve both relationships and the quantity basis. If the system cannot determine the distribution between finished lots, show the possible relationship and uncertainty. Do not invent precision to make the diagram look complete.

Apply the history to the relevant review

Supplier and facility identities let a reviewer connect origin records with sourcing findings. Use facility mapping to keep those references stable. Use evidence management to distinguish source documents from conclusions drawn from them.

The market-access hub connects this operating method to separate EU and US framework pages. Neither a country label nor a custody diagram is a universal clearance. Test whether your team can reproduce the trace, state its limits and respond to the particular question being asked.

Sources and scope

Primary references checked on 4 October 2026. The process examples and implementation suggestions are editorial guidance. Formal standards are distinct from legal requirements.

The data fields, review methods and fictional examples below are editorial implementation suggestions. They are not a universal legal evidence checklist, certification scheme or guarantee of admissibility. Evaluate legal requirements within the relevant framework.

How this resource handles evidence and corrections