Traceability when a manufacturer acts as a retailer

I've just completed our first mock recall and found a traceability gap.

We are 99% a manufacturer/wholesaler, but have occaisional direct retail sales when customers knock on our door.  We've don't  documented the lots sold in these direct sales, so I can only reconcile about 99% of our products. 

Do we need to start documenting these sales with lot numbers (which is a pain in the neck) to get to 100% traceability, or is 99% good enough if we act as a retailer.

Thanks for any thoughts-Krisitina

You need 100%.  You need to at least be able to show that the 1% clearly went to retail. It is analogous to a small store with 5 cases of something.  They may sell one container at a time, but they know that 2 cases have been sold to their customers and 3 cases are still on hand.  They won't have the information on those customers and will have utilize another method of notification in lieu of direct contact, but they know it was sold.  You may not know to which customer in retail it was sold to....but you need to know that it was sold through retail.  If the volume is small enough though it would be an advantage to be able to track those customers in the event of a recall.   

I'm thinking you can set up a system where the retail sales outlet is treated as a single customer/client.  The same documenting that is used to track the sales /product sent to the other customers can be used for the retail outlet.   Then you can track to them as the 1st external customer.