GMP+ for Feed Trade and Storage — A Guide for Trading Companies and Warehouses

Who this certification scope applies to

The GMP+ trade-and-storage scope covers companies that buy feed materials or compound feed from producers or other intermediaries and then resell them — without carrying out any operation on the goods that would qualify as production (mixing, pelleting or other technological processing). This applies both to large trading companies handling significant volumes of grain, meal or feed components, and to smaller regional intermediaries working with a handful of regular suppliers and customers.

The same scope also applies to independent warehouses — facilities whose core activity is storing feed goods, not necessarily combined with their own trading turnover — as well as warehouses operating a 3PL (third-party logistics) model, providing a storage service on behalf of other companies that remain the owners of the stored goods. In both cases the facility physically receives, stores and releases feed goods, even though it is not formally the owner of that goods for the whole storage period.

In practice a company may combine both profiles — running its own trading business while also offering a storage service to other parties in the same facility. The certification scope should then clearly indicate which elements of the activity are covered by GMP+, since this determines which documentation and procedures the auditor will review during the visit.

It is also worth distinguishing a trading company from a purely financial intermediary who merely puts the parties to a transaction in touch, without taking part either in the physical flow of goods or in their formal sale (that is, without buying and selling the goods in its own name). Such an intermediary usually does not fall under GMP+ certification in this scope, because it does not become a party to the supply chain within the meaning of the standard — responsibility for the quality and traceability of the goods then rests entirely with the seller and the buyer, who conclude the transaction directly between themselves. In practice, though, the line between the role of a financial intermediary and that of a trader taking part in the supply chain can be blurred, so it is worth clarifying this point with the certification body before starting the cooperation, if in doubt.

Verifying the origin of goods

Since a trading company does not process the goods, a credible way of verifying where the goods actually come from becomes a key element of its quality system. In practice this means checking whether the supplier holds current GMP+ certification (or a recognised, equivalent system under mutual recognition), gathering documentation confirming that compliance — a copy of the certificate, a registration number that can be verified in the official GMP+ register — and linking a specific delivery to a specific, verified supplier.

Origin verification does not end with a one-off check of the certificate when the cooperation begins. Certificates have a defined validity period and can be suspended or withdrawn, so a trading company should repeat the verification periodically — especially for suppliers it works with on a long-term, regular basis. Good practice is to keep a simple supplier register with the expiry dates of their certificates, so as not to rely purely on the memory of the person responsible for purchasing.

Every delivery received should be linked to documentation confirming its origin — a delivery document identifying the supplier, the batch number and the quantity of goods. Without this link, a trading company loses the ability to show where the goods it subsequently resells actually came from, which, in the event of an incident (for example the detection of contamination somewhere in the chain), makes it impossible to quickly narrow the problem down to a specific delivery.

Stock rotation (FIFO) and storage conditions

A company storing feed goods — whether on its own account or as a service for others — should apply the FIFO principle (first in, first out): goods received earliest should be released first. Failing to follow this rule leads to situations where older batches linger in the warehouse, which, for organic materials, increases the risk of quality loss — mould growth, changes in moisture content, reduced nutritional parameters. Even a simple warehouse system based on batch numbering and receipt dates should support rotation, rather than leaving it entirely to the warehouse operator's judgement at each release.

Storage conditions — temperature, air humidity, and the building's resistance to rainfall and ground moisture — should be matched to the type of goods stored and monitored in a documented way. Materials sensitive to moisture (for example certain meals or additives) require particular attention, since even a brief excursion of air humidity above the acceptable level in a warehouse can trigger mould processes that are not visible at first glance.

Equally important is separating incompatible goods — for example materials with a different allergen status, products intended for different animal species subject to restrictions on certain additives, or feed goods kept apart from non-feed substances stored in the same facility (such as plant protection products or fertilisers). Separation may be physical (dedicated rooms or zones) or — where that is not possible — procedural, with clearly defined storage and labelling rules that limit the risk of accidental contact or a mix-up at release.

Pest protection requires the same elements as at a production plant — regular monitoring (bait stations, checks of entry points into the building), documented inspections and a procedure for responding when pests are detected. In storage facilities, where goods are often kept for longer than at a production plant, the pest-related risk tends to be higher, which is worth factoring into how often checks are carried out.

Traceability during transhipment and batch consolidation

One of the most demanding aspects of trade-and-storage certification is maintaining traceability in situations where goods from several batches are physically combined — for example poured into a shared silo, tank or warehouse bay in bulk. Once such combination has taken place, it is no longer possible to reconstruct exactly how much of the goods from each component batch ended up in a given part of the tank — which is why the documentation must record this at the level of the resulting batch: which output batch (the one being sold on) was formed from which specific input batches.

In practice this means keeping a consolidation register — a record indicating the date of combination, the tank or location where the consolidation took place, and a list of the input batches together with their quantities. Such a record makes it possible, if needed (for example in a product withdrawal or an investigation into the cause of contamination), to identify the pool of suppliers whose goods could have ended up in a given resulting batch — even where the exact proportion can no longer be established.

During transhipment — moving goods between means of transport, silos or packaging — keeping batch marking intact at every stage is essential. Repackaging goods from a large bulk pack into smaller sales units without preserving the link to the original batch number is one of the more common mistakes, and it leads to a loss of the ability to reconstruct the origin of the goods at the point of final sale.

"Pass-through" trading — sales without physical storage

A specific model of trading activity is so-called pass-through trading — a situation in which a trading company buys goods from a producer and resells them to a customer, but the goods never physically enter its own warehouse. Delivery takes place directly from the producer to the end customer, and the trading company acts as an intermediary in the transaction and in the documentation, not in the physical flow of goods.

Despite the lack of physical contact with the goods, the trading company's responsibility in such a model does not disappear — it still has to verify that the goods come from a supplier meeting GMP+ requirements, and to ensure that the sales documentation clearly identifies the actual supplier and batch of goods, even though it never physically had the goods at its disposal. In practice, an auditor checking such cases will focus above all on the completeness of the document chain: the order placed with the producer, confirmation of shipment directly to the customer, and the sales invoice — all of which must consistently point to the same batch of goods.

The pass-through model is sometimes mistakenly treated as exempting a trading company from certification obligations, on the grounds that it does not have a warehouse of its own. In reality, GMP+ treats such a company as a full link in the supply chain — it is the one that concludes the commercial contract, and it is the one responsible for the quality of the transaction documentation, regardless of the fact that the physical flow of goods bypasses its infrastructure.

Supplier management at a trading company

At a production plant, supplier management is backed up by the company's own process control — even if a supplier's raw material raises doubts, the producer has a chance to catch the problem during goods-in inspection or in the course of further processing. A purely trading company does not have this extra layer of control — goods pass from the supplier straight to sale or storage, without any processing, which is why the quality of supplier verification takes on proportionally greater importance.

In practice this means a trading company should maintain a more formalised list of approved suppliers than it might for occasional, one-off purchases — with clear approval criteria (a valid GMP+ certificate or equivalent, a sound delivery history, no reported non-conformities), periodic re-assessment, and a procedure for responding when a problem is found at a supplier — for example suspending the cooperation pending clarification.

It does happen that a trading company uses suppliers outside the GMP+ system, operating under programmes recognised as equivalent or subject to other, national oversight mechanisms. In such cases GMP+ allows the purchase, provided there has been an appropriate risk assessment and documented reasoning for why the company considered that particular supplier a reliable source of goods — a supplier's own declaration, with no verifiable basis behind it, is usually not enough.

It is also worth remembering that the list of approved suppliers should not be a static document, drawn up once for the first audit and then forgotten. In practice, well-organised trading companies assign each supplier a risk level — depending, for example, on the type of goods, the history of the cooperation or the number of previously identified non-conformities — and vary the frequency of re-verification accordingly. A supplier with a long-established, trouble-free relationship may be subject to less frequent verification than a new contractor or a supplier of goods with a higher risk profile, such as materials more susceptible to contamination.

Storage as a service for other companies (external warehouse, 3PL)

A warehouse providing storage services to several different clients at once faces an extra challenge that a warehouse handling only its own goods does not — it must precisely account for which batches in the facility belong to which client, even where goods belonging to different clients are physically stored in the same type of tank or the same bay.

This calls for a record-keeping system linked to each batch — not only by type of goods but also by owner — together with clear rules for physical or at least locational separation (for example dedicated sections of a bay, marked with a client number), so that goods are not mixed up between batches belonging to different clients when they are released. For goods stored in bulk in silos — where physical separation of different clients' batches tends to be harder — the warehouse should have a clearly established rule for assigning a specific silo to a specific owner of goods for a given period.

The contract between the warehouse and the client should set out how responsibility for the individual elements of the quality system is divided — who is responsible for storage conditions, who for pest control at the facility, and who for the documentation confirming the origin of the goods before they are received into storage. Without such a division, it is easy to end up in a situation where both parties assume that a given element is the other side's responsibility — something that only becomes apparent during an audit or an incident.

Export and import in feed trading

Trading companies dealing in feed goods internationally — both within the European Union and beyond it — should pay particular attention to the consistency between the documentation accompanying the shipment and the company's internal records. The batch number, quantity and description of the goods on export or import documents should be unambiguously traceable to the internal traceability record — just as with domestic trade, except that in this case the documentation tends to be more extensive and is additionally subject to formal requirements not directly related to GMP+.

In international trade it is also important to make sure that the foreign supplier or customer actually takes part in the GMP+ system or in a programme recognised as equivalent — the certification status of a foreign partner is worth verifying just as carefully as that of a domestic supplier, since geographical distance and a different documentation language do not exempt a trading company from its obligation to verify the origin of the goods. In practice it is worth agreeing a uniform format for exchanging batch documents with a foreign partner already at the stage of establishing the cooperation, which considerably simplifies later verification during an audit.

How the trade-and-storage scope differs from the production scope

The most significant difference from the GMP+ production scope is that a trading company does not process the goods — so the whole group of requirements relating to control of the manufacturing process falls away: validating mixing homogeneity, a production sequence limiting cross-contamination between formulations, or checking the accuracy of dosing equipment. These elements simply do not apply where goods enter and leave the company in unchanged form.

What remains are the requirements shared across the whole GMP+ system, described in more detail on the GMP+ standard requirements page — a documented quality management system, a HACCP analysis (adapted to the specifics of trading and storage rather than to a manufacturing process), batch traceability and supplier management. In practice, a HACCP analysis for a trading company focuses on the risks associated with storage, transhipment and transport of the goods, rather than on the parameters of a technological process the company simply does not run.

A company that, alongside trading, also runs its own transport should additionally look at the requirements described on the GMP+ for transport and forwarding page — the transport scope is separate from the trade-and-storage scope and covers different requirements, relating among other things to the cleanliness of means of transport and the sequencing of loads.

Most common non-conformities in audits of trading and storage companies

Based on audit experience at trading companies and warehouses, the most recurring observations concern: a lack of up-to-date verification of supplier certificates (for example relying on a copy of a certificate whose validity has already expired), incomplete documentation of batch consolidation for goods stored in bulk in silos, and a lack of consistency between purchasing documentation and sales documentation in pass-through transactions, where the goods never physically enter the company's warehouse.

At warehouses serving several clients, a frequent problem is insufficient separation of the records for batches belonging to different clients — especially for goods stored in the same type of tank — and the absence of a formal contract setting out how responsibility for the individual elements of the quality system is divided between the warehouse and the owner of the goods. Less frequently mentioned but regularly recurring observations also include: inadequate documentation of FIFO rotation (no record confirming the actual order in which goods were released) and an incomplete log of storage-condition checks, limited to sporadic, unsystematic entries instead of regular monitoring.

Where to start implementation

A good starting point for a trading company is to review its current supplier base for the validity and completeness of the certification documentation it holds — this is precisely the area that most often needs putting in order first, since it forms the foundation for the rest of the work on the quality system. It is also worth tracing a few recent transactions "from order to sales invoice", checking whether the origin of the goods sold can be unambiguously reconstructed at every stage.

For a warehouse, the key first step is assessing the current way batches are separated — whether goods from different suppliers or different clients are, in practice, kept apart in a way that will hold up to an auditor's detailed questions about a specific batch. We describe the general course of implementation and certification, common to all activity scopes covered by GMP+, on the GMP+ certification process page. General information about the GMP+ system itself and its structure can be found on the What is GMP+ page.

In our advisory practice, we recommend that trading companies and warehouses run a simple internal test before the actual certification audit: pick a few batches sold in recent months at random and try to reconstruct their full history yourself — from the purchase, through any consolidation or transhipment, right up to the sale to a specific customer. If such a test reveals gaps in the documentation, it is better to discover them yourself than during the official certification audit, where being unable to answer a question about the origin of a specific batch is one of the more serious non-conformities.

Glossary of terms

Pass-through trading

A trading model in which a company buys and resells goods without physically storing them — the delivery goes directly from the producer to the customer, and the trading company acts as an intermediary in the transaction and the documentation.

FIFO rotation

The "first in, first out" principle — goods received earliest should be the first released from the warehouse, limiting the risk of older batches being kept for too long.

External warehouse (3PL)

A storage facility providing a goods-storage service on behalf of other companies, which remain the owners of the stored goods for the whole storage period.

Origin verification

The process of verifying where purchased goods actually come from — it includes checking the supplier's certification and gathering documentation clearly linked to a specific delivery and batch.

Batch consolidation

The physical combination of goods from several separate input batches (for example in one silo), after which traceability must be maintained at the documentation level, identifying all the component batches.

Approved supplier

A supplier entered on a company's formal list after meeting defined criteria (a valid GMP+ certificate or equivalent, a sound delivery history), subject to periodic re-assessment.