ANIMAL CARE PROGRAM 
GUIDANCE: AUDIT TRAIL REQUIREMENT 
UNDER ANIMAL CONFINEMENT REGULATIONS 
Mission of Animal Care Program 
To serve animal agriculture producers and California consumers by promoting and protecting the welfare and 
care of animals in agriculture in order for Californians to have access to food that is sourced from humanely and sustainably raised animals. 
Purpose 
This guidance document is for buyers of covered product who are relying on a written certiﬁcation from their 
suppliers that covered product  is not from a covered animal  conﬁned in a cruel manner.  This written 
certiﬁcation is based upon an audit trail  and is traceable to producer(s) compliant with all applicable species 
requirements of Proposition 12 (2018) Animal Conﬁnement regulations, Chapter 10 (commencing with section 
1320) of Division 2 of Title 3 of the California Code of Regulations  (3 CCR) sections 1320.1, 1321.1 and 
1322.1. 
As of January 1, 2024, shell eggs , liquid eggs , whole veal meat  and whole pork meat  sold in California are 
required to be from certiﬁed operations  (3 CCR section 1320.1(b), 1321.1(b) and 1322.1(b)). 
This guidance document is for: 
1. Distributors 
This guidance document serves as a companion to the Distributor On-Site Inspection Certiﬁcation  
guidance document.  If you are a distributor , review both guidance documents to prepare for an on-
site inspection as part of distributor certiﬁcation .  
2. Retailer or food processing facilities who are  end-users  and purchase covered products  directly from 
establishments under mandatory inspection under the Federal Meat Inspection Act or the Egg Products 
Inspection Act. 
If you are a retailer or food processor end-user  who purchases covered product  directly from a facility 
under mandatory inspection under the Federal Meat Inspection Act or the Egg Products Inspection Act and that facility is not a registered distributor  with the Animal Care program, this guidance document 
will show you how to comply with the written certiﬁcation requirements of 3 CCR sections 1320.8(b), 1321.8(b), and 1322.8(b). 
3. Any buyer of covered products  who is relying on a written certiﬁcation from their supplier to ensure 
they are buying compliant covered products . 
For purposes of section 25993.1 of the California Health and Safety Code , any written certiﬁcation 
from a supplier to a buyer engaged in commercial sales  of compliant covered product  shall be based 
upon an audit trail  and shall be traceable to a certiﬁed operation . 3 CCR sections 1320.8(a), 
1321.8(a), and 1322.8(a). 
Audit trail means records that are in suﬃcient detail to document the identiﬁcation, source, supplier , transfer of 
ownership, transportation, storage, segregation, handling, packaging, distribution, and sale of covered 
products  that were derived from covered animals  conﬁned in compliance with Animal Conﬁnement regulations, 
and from egg producers , veal producers , or pork producers  that hold a valid certiﬁcation  as a certiﬁed 
operation . 3 CCR sections 1320(b), 1321(b) and 1322(b). 
Additional key terms italicized  in this guidance are described on Key Terms for Stakeholders  guidance 
document. 
EST . 01/2024 Audit Trail Requirements 
Animal Health and Food Safety Services | 1220 N Street, Sacramento, California 95814
Telephone: 916.900.5187 | Fax: 916.900.5332 | www.cdfa.ca.gov/ahfss 1   ANIMAL CARE PROGRAM 
GUIDANCE: AUDIT TRAIL REQUIREMENT 
UNDER ANIMAL CONFINEMENT REGULATIONS 
Distributor Audit Trail Requirement 
As of January 1, 2024, shell eggs , liquid eggs , whole veal meat  and whole pork meat sold  in California are 
required to be from certiﬁed operations  (3 CCR section 1320.1(b), 1321.1(b) and 1322.1(b)).  For a distributor  
they are required to demonstrate through an audit trail  that covered product  is traceable back to a certiﬁed 
operation  and this will be veriﬁed during their annual certiﬁcation  by a certifying agent . 
The certiﬁed operation  as a source of the compliant covered product  as shown through an audit trail  can be a 
certiﬁed producer  or a certiﬁed distributor . 
A certiﬁed producer is an egg producer , veal producer or pork producer  operation, or portion of such an 
operation, in the case of a split operation , that is certiﬁed by a certifying agent  as complying with all applicable 
requirements under Animal Conﬁnement regulations. 
A certiﬁed distributor  is an egg distributor , veal distributor  or pork distributor , or portion of such an operation, in 
the case of a split operation , that is certiﬁed by a certifying agent  as complying with all applicable requirements 
under Animal Conﬁnement regulations. 
To comply with applicable 3 CCR sections 1320.5(b), 1320.5(c), 1321.5(b), 1321.5(c), 1322.5(b), 1322.5(c), 
and 1326.2(b)(2), a distributor  is required to maintain the following records related to an audit trail : 
1. Records  suﬃcient for purposes of an audit trail  as deﬁned in Animal Conﬁnement regulations and the 
applicable recordkeeping requirements described in 3 CCR section 1326.2(b)(2). 3 CCR sections 1320.5(b), 1321.5(b), and 1322.5(b) 
2. Records  documenting in a traceable manner that covered product  being distributed for commercial 
sale into or within California originates from compliant producers . 3 CCR sections 1320.5(c), 1321.5(c), 
and 1322.5(c) 
AND 
3. Records  documenting the identiﬁcation, source, supplier, transfer of ownership, transportation, 
storage, segregation, handling, packaging, distribution, and sale of covered products  that were derived 
from compliant producers . 3 CCR section 1326.2(b)(2) 
Review the diﬀerent scenarios outlined below to further understand this audit trail  requirement for registered 
distributors . The following scenarios are relevant to the designated covered product  category: 
Scenario 1: General for all covered products 
For Shell Eggs  and Liquid Eggs : Scenarios 3, 4, 5, 6, and 7 
For Whole Pork Meat : Scenarios 8, 9 and 10 
For Whole Veal Meat: Scenarios 11, 12 and 13
 
EST . 01/2024 Audit Trail Requirements 
Animal Health and Food Safety Services | 1220 N Street, Sacramento, California 95814   Telephone: 916.900.5187 | Fax: 916.900.5332 | www.cdfa.ca.gov/ahfss 2   ANIMAL CARE PROGRAM 
GUIDANCE: AUDIT TRAIL REQUIREMENT 
UNDER ANIMAL CONFINEMENT REGULATIONS 
Retailer and Food Processor End-User Audit Trail Requirement Purchasing Covered Products 
Directly from Establishments Under Mandatory Federal Inspection Who Are Not Registered 
Distributors 
As of January 1, 2024, shell eggs , liquid eggs , whole veal meat  and whole pork meat  sold in 
California are required to be from certiﬁed operations  (3 CCR section 1320.1(b), 1321.1(b) and
1322.1(b)).  For retailers and food processors who are end-users  and purchase covered products  
directly from establishments under mandatory inspection under the Federal Meat Inspection Act or 
the Egg Products Inspection Act and those facilities are not registered distributors  with the Animal 
Care Program are required to maintain records which include: 
1. Records  documenting written certiﬁcations that meet the requirements for covered product  
received during the preceding 12-month period. 
2. Records  documenting the address of the location where the retailer or food processor , as the 
buyer, takes physical possession  of covered product  for each sales transaction. 
AND 
3. Make these required records available on-site for inspection by the Animal Care Program 
upon request. Electronic records are considered on-site if they are accessible from an on-site location. 
Review the diﬀerent scenarios outlined below to further understand this audit trail  requirement of end-
users purchasing covered products  directly from establishments under mandatory inspection under 
the Federal Meat Inspection Act or Egg Products Inspection Act who are not registered distributors . 
The following scenario is relevant to the designated covered product  category: 
Scenario 2: General for all covered products  
For Shell Eggs  and Liquid Eggs : Scenario 14 
For Whole Pork Meat: Scenario 15 
For Whole Veal Meat: Scenario 16 
EST . 01/2024 Audit Trail Requirements 
Animal Health and Food Safety Services | 1220 N Street, Sacramento, California 95814   Telephone: 916.900.5187 | Fax: 916.900.5332 | www.cdfa.ca.gov/ahfss 3   ANIMAL CARE PROGRAM 
GUIDANCE: AUDIT TRAIL REQUIREMENT 
UNDER ANIMAL CONFINEMENT REGULATIONS 
SCENARIO 1 SCENARIO 2 
Scenario 1 – General audit trail  (all types of covered products) for distributors:  
Distributor  (green box) who is requesting certiﬁcation  must show through an audit trail  that 
covered product  is traceable back to a certiﬁed operation . 
CERTIFIED PRODUCER(S) 
PROCESSOR 
BROKER 
DISTRIBUTOR 
Blue arrows show the ﬂow of covered product through the supply chain from the certiﬁed 
producer  to the distributor  requesting certiﬁcation .  Green arrows  show steps back through 
the supply chain that an audit trail will need to include to fulﬁll the requirement of covered 
product traceable back to a certiﬁed operation . In this scenario, the audit trail is back to a 
certiﬁed producer . Scenario 2 – General audit trail (all types of covered products) for retailer or food 
processor end-users who are purchasing covered product directly from establishments 
under mandatory inspection under the Federal Meat Inspection Act or the Egg Products 
Inspection Act and those establishments are not registered distributors  with the Animal Care 
Program. 
CERTIFIED PRODUCER(S) 
PROCESSOR UNDER MANDATORY 
INSPECTION UNDER THE FEDERAL 
MEAT INSPECTION ACT OR EGG 
PRODUCTS INSPECTION ACT 
RETAILER OR FOOD PROCESSOR 
WHO IS AN END-USER 
Blue arrows show the ﬂow of covered product through the supply chain from the certiﬁed 
producer  to the retailer or food processor  end-user.  Green arrows show steps back through 
the supply chain that a written certiﬁcation , which is based on an audit trail, will need to include 
to fulﬁll the requirement of covered product  traceable back to a certiﬁed operation . Retailers 
and food processors who are end-users  and purchase covered products directly from 
establishments under mandatory inspection will need to maintain this written certiﬁcation  of 
covered products they purchase for one year.  In this scenario, the audit trail is back to a 
certiﬁed producer  because there is no distributor . 
EST . 01/2024 Audit Trail Requirements 
Animal Health and Food Safety Services | 1220 N Street, Sacramento, California 95814
Telephone: 916.900.5187 | Fax: 916.900.5332 | www.cdfa.ca.gov/ahfss 4   ANIMAL CARE PROGRAM 
GUIDANCE: AUDIT TRAIL REQUIREMENT 
UNDER ANIMAL CONFINEMENT REGULATIONS 
SCENARIO 3 
Scenario 3 – Egg: Egg Distributor  (green box) who is requesting certiﬁcation  must show 
through an audit trail that shell eggs are traceable back to a certiﬁed operation . 
CERTIFIED EGG PRODUCER(S) 
PROCESSOR 
EGG DISTRIBUTOR SCENARIO 4 
Scenario 4 – Egg: Egg Distributor  B (green box) who is requesting certiﬁcation  must show 
through an audit trail that shell eggs are traceable back to a certiﬁed operation . 
CERTIFIED EGG PRODUCER(S) 
PROCESSOR 
DISTRIBUTOR A 
EGG DISTRIBUTOR B 
Blue arrows show the ﬂow of shell eggs through the supply chain from the certiﬁed egg 
producer  to Egg Distributor  B. Green arrows show steps back through the supply chain that 
Blue arrows show the ﬂow of shell eggs through the supply chain from the egg producer  to the an audit trail will need to include to fulﬁll the requirement of shell eggs traceable back to a 
egg distributor . Green arrows show steps back through the supply chain that an audit trail will certiﬁed operation . In this scenario, the audit trail is back to a certiﬁed egg producer . 
need to include to fulﬁll the requirement of shell eggs traceable back to a certiﬁed operation . In 
this scenario, the audit trail is back to a certiﬁed egg producer . 
EST . 01/2024 Audit Trail Requirements 
Animal Health and Food Safety Services | 1220 N Street, Sacramento, California 95814   Telephone: 916.900.5187 | Fax: 916.900.5332 | www.cdfa.ca.gov/ahfss 5   ANIMAL CARE PROGRAM 
GUIDANCE: AUDIT TRAIL REQUIREMENT 
UNDER ANIMAL CONFINEMENT REGULATIONS 
SCENARIO 5 
Scenario 5 – Egg: Egg Distributor  B (green box) who is seeking certiﬁcation  must show 
through an audit trail that shell eggs are traceable back to a certiﬁed operation .  In this 
example, Egg Distributor  B is buying shell eggs from another certiﬁed Egg Distributor  (Egg 
Distributor  A). 
CERTIFIED EGG PRODUCER(S) 
PROCESSOR 
EGG DISTRIBUTOR A 
(CERTIFIED DISTRIBUTOR) 
EGG DISTRIBUTOR B 
Blue arrows show the ﬂow of shell eggs through the supply chain from the certiﬁed egg 
producer  to Egg Distributor  B. Green arrows show steps back through the supply chain that 
an audit trail Egg Distributor  B will need to include to fulﬁll the requirement of shell eggs 
traceable back to a certiﬁed operation . In this scenario, Egg Distributor  B's audit trail is only 
back to Egg Distributor  A because Egg Distributor  A is a certiﬁed egg distributor .  Therefore, the 
audit trail for Egg Distributor  B stops at the point in the supply chain where Egg Distributor  B 
can show the shell eggs are traceable back to certiﬁed Egg Distributor  A. When Egg Distributor  
A is certiﬁed, they will show through an audit trail that shell eggs they distribute are traceable 
back to a certiﬁed egg producer  (similar to Scenario 3 – Egg in this guidance document). 
EST . 01/2024 SCENARIO 6 
Scenario 6 – Egg: Egg Distributor  (green box) who is seeking certiﬁcation  must show 
through an audit trail  that liquid eggs  are traceable back to a certiﬁed operation . 
CERTIFIED EGG PRODUCER(S) 
BREAKING PLANT UNDER MANDATORY 
USDA INSPECTION (UNDER EGG
PRODUCTS INSPECTION ACT) 
EGG DISTRIBUTOR 
Blue arrows show the ﬂow of liquid eggs through the supply chain from the certiﬁed egg 
producer  to the Egg Distributor  seeking certiﬁcation . Green arrows show steps back through 
the supply chain that the audit trail will need to include to fulﬁll the requirement of liquid eggs 
traceable back to a certiﬁed operation . In this scenario, the audit trail is back to a certiﬁed egg 
producer . 
Audit Trail Requirements 
Animal Health and Food Safety Services | 1220 N Street, Sacramento, California 95814   Telephone: 916.900.5187 | Fax: 916.900.5332 | www.cdfa.ca.gov/ahfss 6     ANIMAL CARE PROGRAM 
GUIDANCE: AUDIT TRAIL REQUIREMENT 
UNDER ANIMAL CONFINEMENT REGULATIONS 
SCENARIO 7 
Scenario 7 – Egg: Egg Distributo r B (green box) who is seeking certiﬁcation  must show 
through an audit trail that liquid eggs are traceable back to a certiﬁed operation . 
CERTIFIED EGG PRODUCER(S) 
BREAKING PLANT UNDER MANDATORY 
USDA INSPECTION (UNDER EGG
PRODUCTS INSPECTION ACT) 
(VOLUNTARILY CHOSE TO BECOME 
CERTIFIED EGG DISTRIBUTOR A) 
EGG DISTRIBUTOR B 
Blue arrows show the movement of liquid eggs through the supply chain from the certiﬁed egg 
producer  to Egg Distributor  B who is demonstrating their compliance with audit trail 
requirement in this scenario. Green arrows show steps back through the supply chain that 
Egg Distributor  B's audit trail will need to include to fulﬁll the requirement of liquid eggs 
traceable back to a certiﬁed operation .  In this scenario, the audit trail for Egg Distributor  B is 
back to a certiﬁed egg distributor  (Egg Distributor A).  Egg Distributor  A is a breaking plant 
under mandatory USDA inspection under the Egg Products Inspection Act who has voluntarily 
chosen to become a certiﬁed egg distributor .  Therefore, the audit trail for Egg Distributor  B 
stops at the point in the supply chain where Egg Distributor  B can show the liquid eggs are 
traceable back to certiﬁed Egg Distributor A.  When Egg Distributor  A is certiﬁed, they will show 
through an audit trail that liquid eggs are traceable back to a certiﬁed egg producer  (similar to 
Scenario 3 – Egg in this guidance document). 
EST . 01/2024  SCENARIO 8 
Scenario 8 – Pork: Pork Distributor  (green box) who is seeking certiﬁcation  must show 
through an audit trail  that whole pork meat  is traceable back to a certiﬁed operation . 
CERTIFIED PORK PRODUCER(S) 
FINISHING FARM 
PROCESSOR UNDER MANDATORY 
INSPECTION UNDER FEDERAL 
MEAT INSPECTION ACT 
BROKER 
PORK DISTRIBUTOR 
Blue arrows show the movement of animals and whole pork meat through the supply chain 
from the pork producer  to the pork distributor .  Green arrows show steps back through the 
supply chain that the Pork Distributor's audit trail will need to include to fulﬁll the requirement of 
whole pork meat traceable back to a certiﬁed operation .  In this scenario, the audit trail is back 
to a certiﬁed pork producer . 
Audit Trail Requirements 
Animal Health and Food Safety Services | 1220 N Street, Sacramento, California 95814   Telephone: 916.900.5187 | Fax: 916.900.5332 | www.cdfa.ca.gov/ahfss 7   ANIMAL CARE PROGRAM 
GUIDANCE: AUDIT TRAIL REQUIREMENT 
UNDER ANIMAL CONFINEMENT REGULATIONS 
SCENARIO 9 
Scenario 9 – Pork: Pork Distributor  B (green box) who is seeking certiﬁcation  must show 
through an audit trail that whole pork meat is traceable back to a certiﬁed operation . 
CERTIFIED PORK PRODUCER(S) 
NURSERY FARM 
FINISHING FARM 
PROCESSOR UNDER MANDATORY INSPECTION 
UNDER FEDERAL MEAT INSPECTION ACT WHO 
IS A CERTIFIED PORK DISTRIBUTOR (VOLUNTARILY 
CHOSE TO BECOME CERTIFIED PORK DISTRIBUTOR A) 
BROKER 
PORK DISTRIBUTOR B 
Blue arrows show the movement of animals and whole pork meat through the supply chain 
from the certiﬁed pork producer  to Pork Distributor  B who is demonstrating their compliance
with the audit trail requirement in this scenario. Green arrows show steps back through the 
supply chain that Pork Distributor  B's audit trail will need to include to fulﬁll the requirement of 
whole pork meat traceable back to a certiﬁed operation .  Pork Distributor  B's audit trail is back 
to Pork Distributor  A, a processor under mandatory USDA inspection under the Federal Meat 
Inspection Act who has voluntarily chosen to become a certiﬁed pork distributor .  The audit trail 
for Pork Distributor  B stops at the point in the supply chain where Pork Distributor  B can show 
whole pork meat is traceable back to certiﬁed Pork Distributor  A.  When Pork Distributor  A is 
certiﬁed, they will be required to show through an audit trail that whole pork meat is traceable 
back to a certiﬁed pork producer  (similar to Scenario 8 – Pork in this guidance document). 
EST . 01/2024 SCENARIO 10 
Scenario 10 – Pork: Pork Distributor  B (green box) who is seeking certiﬁcation  must show 
through an audit trail  that whole pork meat is traceable back to a certiﬁed operation . 
CERTIFIED PORK PRODUCER(S) 
NURSERY FARM 
FINISHING FARM 
PROCESSOR UNDER MANDATORY INSPECTION 
UNDER FEDERAL MEAT INSPECTION ACT 
BROKER (CERTIFIED PORK DISTRIBUTOR A) 
PORK DISTRIBUTOR B 
Blue arrows show the movement of animals and whole pork meat through the supply chain 
from the certiﬁed pork producer  to Pork Distributor  B who is demonstrating their compliance
with the audit trail requirement in this scenario. Green arrows show steps back through the 
supply chain that Pork Distributor  B's audit trail will need to include to fulﬁll the requirement of 
whole pork meat traceable back to a certiﬁed operation .  In this scenario, the audit trail for Pork 
Distributor  B is back to a certiﬁed pork distributor , Broker (Pork Distributor  A).  When Pork 
Distributor A is certiﬁed, they will be required to show through an audit trail that whole pork 
meat is traceable back to a certiﬁed operation  (similar to Scenario 8 – Pork in this guidance 
document). 
Audit Trail Requirements 
Animal Health and Food Safety Services | 1220 N Street, Sacramento, California 95814   Telephone: 916.900.5187 | Fax: 916.900.5332 | www.cdfa.ca.gov/ahfss 8   ANIMAL CARE PROGRAM 
GUIDANCE: AUDIT TRAIL REQUIREMENT 
UNDER ANIMAL CONFINEMENT REGULATIONS 
SCENARIO 11 
Scenario 11 – Veal: Veal Distributor  B (green box) who is seeking certiﬁcation  must show 
through an audit trail that whole veal meat is traceable back to a certiﬁed operation . 
CERTIFIED VEAL PRODUCER(S) 
PROCESSOR UNDER MANDATORY 
INSPECTION UNDER FEDERAL 
MEAT INSPECTION ACT 
BROKER 
VEAL DISTRIBUTOR 
Blue arrows show the movement of calves and whole veal meat through the supply chain 
from the veal producer  to the veal distributor .  Green arrows show steps back through the 
supply chain that the Veal Distributor's audit trail will need to include to fulﬁll the requirement of 
whole veal meat traceable back to a certiﬁed operation .  In this scenario, the audit trail is back 
to a certiﬁed veal producer . 
EST . 01/2024 SCENARIO 12 
Scenario 12 – Veal: Veal Distributor  B (green box) who is seeking certiﬁcation  must show 
through an audit trail  that whole veal meat  is traceable back to a certiﬁed operation . 
CERTIFIED VEAL PRODUCER(S) 
PROCESSOR UNDER MANDATORY 
INSPECTION UNDER FEDERAL 
MEAT INSPECTION ACT 
CERTIFIED VEAL DISTRIBUTOR A 
VEAL DISTRIBUTOR B 
Blue arrows show the movement of calves and whole veal meat through the supply chain 
from the veal producer  to Veal Distributor  B. Green arrows show steps back through the 
supply chain that Veal Distributor  B's audit trail will need to include to fulﬁll the requirement of 
whole veal meat traceable back to a certiﬁed operation .  In this scenario, the audit trail for Veal 
Distributor  B is back to a certiﬁed veal distributor , Certiﬁed Veal Distributor  A.  When Veal 
Distributor  A is certiﬁed, they will be required to show through an audit trail that whole veal meat 
is traceable back to a certiﬁed operation  (similar to Scenario 11 – Veal in this guidance
document). 
Audit Trail Requirements 
Animal Health and Food Safety Services | 1220 N Street, Sacramento, California 95814   Telephone: 916.900.5187 | Fax: 916.900.5332 | www.cdfa.ca.gov/ahfss 9   ANIMAL CARE PROGRAM 
GUIDANCE: AUDIT TRAIL REQUIREMENT 
UNDER ANIMAL CONFINEMENT REGULATIONS 
SCENARIO 13 
Scenario 13 – Veal: Veal Distributor  B (green box) who is seeking certiﬁcation  must show 
through an audit trail that whole veal meat is traceable back to a certiﬁed operation . 
CERTIFIED VEAL PRODUCER(S) 
PROCESSOR UNDER MANDATORY INSPECTION 
UNDER FEDERAL MEAT INSPECTION ACT WHO 
IS A CERTIFIED VEAL DISTRIBUTOR (VOLUNTARILY 
CHOSE TO BECOME CERTIFIED VEAL DISTRIBUTOR A) 
BROKER 
VEAL DISTRIBUTOR B 
Blue arrows show the movement of calves and whole veal meat through the supply chain 
from the certiﬁed veal producer  to Veal Distributor  B who is demonstrating their compliance 
with the audit trail requirement in this scenario. Green arrows show steps back through the 
supply chain that Veal Distributor  B's audit trail will need to include to fulﬁll the requirement of 
whole veal meat traceable back to a certiﬁed operation .  Veal Distributor  B's audit trail is back 
to Veal Distributor  A, a processor under mandatory USDA inspection under the Federal Meat 
Inspection Act who has voluntarily chosen to become a certiﬁed veal distributor .  The audit trail 
for Veal Distributor  B stops at the point in the supply chain where Veal Distributor  B can show 
whole veal meat  is traceable back to certiﬁed Veal Distributor  A.  When Veal Distributor  A is 
certiﬁed, they will be required to show through an audit trail that whole veal meat is traceable 
back to a certiﬁed operation  (similar to Scenario 11 – Veal in this guidance document). 
EST . 01/2024 SCENARIO 14 
Scenario 14 – Eggs: for retailer or food processor end-users  who are purchasing shell 
eggs and liquid eggs  directly from establishments under mandatory inspection under the
Egg Products Inspection Act and those establishments are not registered distributors  with 
the Animal Care Program. 
CERTIFIED EGG PRODUCER(S) 
BREAKING PLANT UNDER MANDATORY 
USDA INSPECTION (UNDER EGG
PRODUCTS INSPECTION ACT) 
RETAILER OR PROCESSOR 
WHO IS AN END-USER 
Blue arrows show the ﬂow of shell eggs and liquid eggs through the supply chain from the 
certiﬁed egg producer  to the retailer or food processor end-user .  Green arrows show steps 
back through the supply chain that a written certiﬁcation , which is based on an audit trail, will 
need to include to fulﬁll the requirement of shell eggs and liquid eggs traceable back to a 
certiﬁed operation . Retailers and food processors who are end-users  and purchase covered 
products directly from establishments under mandatory inspection will need to maintain this 
written certiﬁcation  of shell eggs and liquid eggs they purchase for one year.  In this scenario, 
the audit trail is back to a certiﬁed egg producer  because there is no egg distributor . 
Audit Trail Requirements 
Animal Health and Food Safety Services | 1220 N Street, Sacramento, California 95814   Telephone: 916.900.5187 | Fax: 916.900.5332 | www.cdfa.ca.gov/ahfss 10   ANIMAL CARE PROGRAM 
GUIDANCE: AUDIT TRAIL REQUIREMENT 
UNDER ANIMAL CONFINEMENT REGULATIONS 
SCENARIO 15 
Scenario 15 – Whole Pork Meat: for retailer or food processor end-users  who are purchasing 
whole pork meat directly from establishments under mandatory inspection under the Federal 
Meat Inspection Act and those establishments are not registered distributors  with the Animal 
Care Program. 
CERTIFIED PORK PRODUCER(S) 
NURSERY FARM 
FINISHING FARM 
PROCESSOR UNDER MANDATORY INSPECTION 
UNDER FEDERAL MEAT INSPECTION ACT 
RETAILER OR FOOD PROCESSOR 
WHO IS AN END-USER 
Blue arrows show the ﬂow of whole pork meat through the supply chain from the certiﬁed pork 
producer  to the retailer or food processor end-user .  Green arrows show steps back through 
the supply chain that a written certiﬁcation , which is based on an audit trail, will need to include 
to fulﬁll the requirement of whole pork meat traceable back to a certiﬁed operation . Retailers 
and food processors who are end-users  and purchase covered products directly from 
establishments under mandatory inspection will need to maintain this written certiﬁcation  of 
whole pork meat they purchase for one year.  In this scenario, the audit trail is back to a 
certiﬁed pork producer  because there is no pork distributor. 
EST . 01/2024 SCENARIO 16 
Scenario 16 – Whole Veal Meat: for retailer or food processor end-users  who are 
purchasing whole veal meat  directly from establishments under mandatory inspection
under the Federal Meat Inspection Act and those establishments are not registered distributors  with the Animal Care Program. 
CERTIFIED VEAL PRODUCER(S) 
PROCESSOR UNDER MANDATORY 
INSPECTION UNDER THE FEDERAL 
MEAT INSPECTION ACT 
RETAILER OR PROCESSOR 
WHO IS AN END-USER 
Blue arrows show the ﬂow of whole veal meat through the supply chain from the certiﬁed veal 
producer  to the retailer or food processor end-user .  Green arrows show steps back through 
the supply chain that a written certiﬁcation , which is based on an audit trail, will need to include 
to fulﬁll the requirement of whole veal meat traceable back to a certiﬁed operation . Retailers 
and food processors who are end-users  and purchase covered products directly from 
establishments under mandatory inspection will need to maintain this written certiﬁcation  of 
whole veal meat they purchase for one year.  In this scenario, the audit trail is back to a certiﬁed 
veal producer  because there is no veal distributor . 
Audit Trail Requirements 
Animal Health and Food Safety Services | 1220 N Street, Sacramento, California 95814   Telephone: 916.900.5187 | Fax: 916.900.5332 | www.cdfa.ca.gov/ahfss 11