Contract Packer Responsibilities
Hi, could anyone provide any clarity. Company A sends bulk product, packaging and labels to Company B (SLA in place). Company B packages this product into smaller 'packages' - they do not add any ingredients, nor do they do any extra processing, other than package into smaller containers. Is it necessary for Company B to know the exact composition of the product (heavy metals, pesticide levels etc) - the turnaround time is normally less than 48 hours, so there are no long storage times. Company B is FSSC certified, and has implemented all the necessary controls to ensure that no contaminants are accidently introduced.
Many thanks
Who OWNS the actual finished goods and are they returned to company A?
Hi - Company A owns (and controls) the product, packaging and labels. The repackaged product is returned to Company A.
Company B will definitely need to know enough to meet their own system requirements, and ensure they can handle the material properly - definitely full spec, allergens, manufacturer certification I'd have thought.
Beyond that, what is the regulatory position in RSA?
If they have an obligation to produce food that meets regs in a certain way, they may need to be able to show that the inputs are compliant - otherwise how would one show that the finished product is itself compliant?
Company A has declared all allergens, and all the products packed contain the same allergens (these are included on the labels provided by company A). Training has been given to all staff to ensure no new allergens are introduced. Company B only packs for Company A, so there are no other products involved. So information necessary to conduct a Hazard Analysis has been provided.
The question is in a way, an ethical one - the product as received is returned in the same condition back to company A (turn around time averages 24hrs). As this is proprietary information (Company A), is it necessary for Company B to conduct an analysis to determine (and these are quoted examples) heavy metal content and pesticide levels?
Beyond that, what is the regulatory position in RSA?
If they have an obligation to produce food that meets regs in a certain way, they may need to be able to show that the inputs are compliant - otherwise how would one show that the finished product is itself compliant?
Sorry - further to the above: RSA regulations do cover "Labelling" - all allergens to be declared etc. The labels supplied by Company A do comply. (There are systems in place to ensure correct labels are applied). Company A is the company that is ultimately still responsible and accountable for the final product. (All Company B does is pack it into smaller containers, supplied by Company A).
Product received at Company B is accompanied by a CoC stating that the product complies with the necessary regulations.