Navel orange is one of the characteristic agricultural products in the middle region of china. The traceability system for navel orange can enhance consumer confidence due to the “stained navel orange” incident. Research on the navel orange traceability chain is the foundation and premise of building the traceability system. Based on the analyses of whole food chain of navel orange from origin to market, HACCP is used to evaluate the risk and latent risk of planting, harvesting, processing, packing, transportation and sale, the critical control link and the critical control point of navel orange traceability chain were fixed combined with the actual situation in china. Further, the code of the navel orange traceability is designed based on EAN.UCC system, which includes origin, processing and the end product. This study makes it possible to construct navel orange traceability system.