Traceability Lot Code (TLC)

This glossary term is part of the SG Systems Global regulatory & operations guide library.

Updated January 2026 • FSMA 204 Traceability Lot Code, TLC definition, lot code standards, internal vs external lots, transformation linkage, shipping/receiving KDE capture, 24-hour response, EPCIS alignment, mixed pallet identity • Primarily Food Supply Chain Traceability (FTL foods, FSMA 204 compliance, recall readiness)

Traceability Lot Code (TLC) is the FSMA 204 traceability identity assigned to a specific lot of food—used to link receiving, transformation, and shipping events into a single traceable chain. In practical terms, the TLC is the “primary key” that makes the FSMA 204 dataset work: it ties together the what (product), the which (lot identity), and the where it went (shipments and trading partners) so regulators and trading partners can trace quickly during investigations.

The confusion in real plants is that “lot code” already exists in many systems (ERP batch numbers, supplier lots, pack dates, internal run codes). A TLC is not automatically the same as any one of those. A TLC is the lot code that must be consistently used for traceability purposes across your CTE/KDE recordkeeping. Sometimes your existing lot code can serve as the TLC. Sometimes it cannot—especially if it is ambiguous, reused, not unique, or not consistently applied across packaging and records.

Tell it like it is: the fastest way to break FSMA 204 traceability is to have multiple “lot codes” that mean different things in different departments. Receiving captures supplier lots, production uses internal batch IDs, shipping uses ship dates, and none of it maps cleanly. In a trace request, you end up translating between codes under pressure. A TLC standard fixes that by making one code the canonical trace identity and forcing every event record (receive/transform/ship) to reference it.

“FSMA 204 doesn’t care what you call your lot code. It cares that one code actually links the event chain without translation gymnastics.”

1) What a Traceability Lot Code (TLC) is in FSMA 204

A TLC is the traceability lot identifier that you use in FSMA 204 recordkeeping to connect CTE events. In a practical implementation, the TLC is the lot code that appears in:

• receiving event records (as the lot you received or as the lot you assign),
• transformation event records (as the input TLCs and output TLCs),
• shipping event records (as the TLCs you shipped to a customer or trading partner).

Whether you call it “TLC” internally doesn’t matter. What matters is that one code is consistently used as the trace identity and is retrievable across events.

2) Why the TLC is the “primary key” of FSMA 204 datasets

FSMA 204 data is event-based. Events are connected through identities. The TLC is the identity that connects the chain. If the TLC is inconsistent, the chain breaks and you can’t produce a coherent dataset.

Operationally, the TLC enables:

• fast backward trace (which inputs fed this TLC?),
• fast forward trace (which customers received this TLC?),
• mass balance reconciliation (how much of this TLC exists and where?),
• precise recall scope (which lots are truly impacted?).

Without a stable TLC, every trace request becomes a translation problem between supplier lot codes, internal batch IDs, and shipping paperwork.

3) TLC vs supplier lot vs internal batch number vs pack date

Most facilities already have multiple identifiers. Here’s the blunt operational difference:

Sometimes your internal batch number can be your TLC. Sometimes your pack lot can be your TLC. The rule is: if it doesn’t uniquely and consistently link the chain, it can’t serve as TLC.

4) What makes a TLC valid: uniqueness, clarity, stability

A valid TLC has three properties:

• Uniqueness: the TLC does not repeat across the time horizon that matters for shelf life and trace investigations.
• Clarity: the TLC can be read and captured reliably (print quality, format rules, scanning).
• Stability: the TLC means the same thing everywhere—receiving, production, storage, shipping, and customer-facing documents.

Practical validation rules include:

• fixed format and length (avoid “free-form lot codes”),
• no ambiguous characters where scanning is used (avoid O/0 confusion),
• uniqueness check at assignment (block duplicates),
• controlled mapping between supplier lot and internal TLC (preserve both).

5) How TLCs are assigned at receiving, transformation, and packing

TLC assignment depends on your role and process:

• Receiving: you may receive a lot that is already a TLC (from upstream). You still need to capture it and map it to your internal lot identity if you use one.
• Transformation: when you create new product lots from inputs, you assign new TLCs to outputs (or assign TLCs at pack-out, depending on your lot definition).
• Packing: if your lot definition is “pack lot,” TLC is assigned at pack and applied to cases/labels and shipping data.

The key is that whichever step assigns the TLC, it must be captured as an event with linkage to inputs and to downstream shipments.

6) Mapping strategy: when existing lot codes can serve as TLC

You do not want to create an extra code unless you need it. The simplest approach is to reuse an existing lot code as TLC if—and only if—it satisfies TLC requirements. Practical test:

• does it uniquely identify the trace lot across your enterprise?
• does it appear on product labels and in ship/receive records?
• does it persist through transformations without ambiguity?
• can you export a dataset using it without translation tables?

If the answer is “no,” you need to define a TLC standard and build mapping from supplier lot → internal TLC and from internal batch → TLC where needed.

7) Transformation linkage: preserving TLC through input→output changes

Transformation events are where TLC discipline is tested. Your record must show:

• input TLCs (or input supplier lots mapped to internal TLCs),
• output TLC(s) created,
• quantities consumed and produced (mass balance),
• time and location of transformation.

If you cannot link input lots to output TLCs, you cannot answer the most important trace question: “which finished lots contain this implicated input lot?”

8) Shipping linkage: making the TLC appear in outbound KDE datasets

A TLC that doesn’t appear in shipping records is operationally useless. Your shipping KDE capture must record:

• TLCs shipped (or SSCC/case IDs linked to TLCs),
• quantities shipped by TLC,
• ship-to trading partner, shipment ID (BOL/ASN), event time.

If your ERP ships by SKU only, your TLC discipline will collapse at the exact point where forward trace is needed.

9) Mixed pallets and commingling: preserving TLC precision

Mixed pallets create TLC ambiguity unless you preserve identity at case/pallet level:

• use case labels (GS1-128) that include TLC,
• use SSCC pallet identity linked to contained case/TLC list,
• capture aggregation events when pallets are built or rebuilt,
• block shipment if pallet content doesn’t reconcile to expected TLCs.

If you record “one TLC for the pallet” when it contains multiple TLCs, your trace dataset becomes wrong and you risk under-notification or over-notification.

10) Labeling and scanning: how TLC becomes captureable at speed

TLC discipline fails when it can’t be captured reliably. Practical label rules:

• print TLC in a consistent location and format on cases and pallets,
• use scannable barcodes (GS1-128/DataMatrix where appropriate),
• validate barcode readability and format (no “pretty but unscannable” labels),
• use scan-first receiving and shipping to minimize manual entry.

If operators must type TLCs, error rates rise and traceability slows. Scanning turns TLC into event-time proof.

11) Common TLC failure modes: reuse, ambiguity, translation debt

• Reuse: lot codes repeat by day or shift; not unique enough for shelf life and trace investigations.
• Ambiguity: lot code means different things in different departments (production vs shipping).
• Translation debt: you need spreadsheets to map supplier lots to internal lots and to shipping IDs.
• Pack-date substitution: using dates as “lot codes” without unique sequence control.
• Mixed pallet collapse: multiple TLCs shipped but only one recorded.

Every failure mode results in slower trace response and broader recall scope.

12) Controls that prevent TLC drift: gates, validation, audit trails

Controls matter more than definitions. High-impact TLC controls:

• Uniqueness gate: block duplicate TLC creation.
• Ship confirm gate: block shipment close unless TLCs are captured and eligible (released).
• Transformation gate: block transformation close unless input TLCs and output TLCs are linked.
• Exception discipline: manual entry requires second-person verification and reason.
• Audit trails: edits require reason-for-change; original values preserved.
• Hold enforcement: ineligible TLCs cannot ship or be consumed.

These controls prevent the most common real-world traceability failures: “we meant to capture it” and “we fixed it later.”

13) 24-hour response: how TLC design affects dataset retrieval speed

A clean TLC makes rapid response possible. When you get a trace request, you should be able to:

• search the TLC and immediately retrieve receiving events,
• retrieve transformation linkage to inputs and outputs,
• retrieve shipping events showing who received the TLC,
• reconcile quantities (mass balance),
• export the dataset quickly.

If the TLC requires translation tables, response time increases and error risk rises. That’s why TLC standardization is a compliance and operational efficiency win.

14) EPCIS alignment: representing TLC relationships in event data

If you export event data via EPCIS, TLC relationships are represented through:

• event identifiers and quantity/lot references,
• input/output linkages in transformation events,
• SSCC/case IDs that reference contained TLCs,
• business transaction references (PO/BOL/ASN) tied to events.

Again: EPCIS is only as good as your TLC discipline. If TLC is ambiguous, EPCIS exports will be ambiguous too.

15) Testing TLC readiness: mock recalls and dead-end drills

To prove TLC discipline, run two tests:

• Forward trace test: pick a TLC and produce who received it, shipment IDs, quantities, and on-hand balance.
• Backward trace test: pick a TLC and produce which input lots fed it (supplier lots and transformation linkages).

If either test requires manual translation spreadsheets, your TLC standard is not working as the primary key.

16) Copy/paste readiness scorecard

Use this to evaluate whether your lot code can serve as TLC.

17) Failure patterns: how TLC gets “implemented” without working

• TLC defined but not enforced. People still ship by SKU; TLC never appears in shipping records.
• TLC exists only in production. Transformation link exists, but outbound lacks TLC capture.
• Multiple lot codes still in use. Warehouse, QA, and production each use different identifiers.
• Mixed pallet shortcut. Pallet shipped with multiple TLCs but recorded as one.
• Manual entry culture. TLC typed frequently; errors and drift accumulate.
• Backfilled corrections. TLC “fixed later” under audit pressure; credibility suffers.

A TLC program works only when it is the enforced identity across all event records, not just a definition in a policy.

18) How this maps to V5 by SG Systems Global

V5 supports TLC discipline by making lot identity the spine of receiving, transformation, and shipping event capture:

• scan-driven receiving captures supplier lots and maps to internal TLCs,
• transformation records link input TLCs to output TLCs with quantities,
• shipping KDE capture ties shipped TLCs to customers, shipments, and SSCC/case identities,
• hold/release gates prevent shipping of ineligible TLCs,
• rapid exports support 24-hour response datasets and mock recalls,
• EPCIS-ready event structures support standardized exchange where required.

These capabilities align across V5 WMS, V5 MES, and integrations via V5 Connect API.

19) Extended FAQ

Q1. Can our existing lot code be the TLC?
Yes if it is unique, consistently applied across receive/transform/ship, and captured at event time in your KDE records. If it requires translation tables, it’s not functioning as TLC.

Q2. Do we need to print “TLC” on labels?
You don’t need the letters “TLC.” You need the traceability lot code itself to be present and scannable on packaging and tied to event records.

Q3. What’s the biggest TLC risk in warehouses?
Mixed pallets and partials. If you lose case-level lot identity during breakdown and rebuild, your forward trace becomes broad and unreliable.

Q4. How do we handle supplier lots vs TLC?
Preserve supplier lots as received and map them to internal lots/TLCs. Never overwrite supplier lot identity; you need it for one-step-back traceability.

Q5. How do we prove TLC readiness?
Run a mock recall: pick a TLC and produce the complete dataset (receive/transform/ship) with quantities that reconcile. If it’s fast and consistent, your TLC is working.

Related Reading (keep it practical)
TLC discipline is only real when it is enforced in receiving, preserved through transformations, and captured at shipping with fast dataset exports aligned to 24-hour response expectations. If you still need translation spreadsheets, your TLC standard isn’t finished.