Let me try again and hopefully not delete half my sentences in mid-flow so I make more sense, 9which admittedly would be a first for me):
With a HACCP plan doesn't mean you necessarily HAVE to have any CCP's. If you can show that you thoroughly assessed your processes and your pre-requisite programs are robust enough and answer any safety issues, you will be fine, you don't necessarily need CCP's. Just show your pre-req's address the issues.
If you create artificial CCP's, it will only be an unnecessary and time consuming endeavor that really has no value added. And will ultimately cause you more problems. It is a good way to set yourself up for trouble.
Make sure though that your allergen program is strong. Are these bottled in glass or plastic? If glass then you may need to make sure you have a very strong glass control program also.
There that make more sense?