Customer is requesting a set of labelled empty food pouches?

Hi everyone!

One of a regular customer is requesting a set of labelled empty food pouches from some products we do private labels for them. But is this can be a nonconformance according to USDA organic, FDA and FSSC 22000 certification guidelines?

Hi Nalathu. Not clear, please elaborate.

That sounds like it violates a good label control program on multiple levels.  You can't control what that customer will place in them, not to mention their filling of those pouches would be outside the HACCP program you use to fill them.  And unless they can fill in the lot code info on their own, you'd be pre-labeling way too far in advance to control the input.

Hard pass in my book.

jfrey123 brings up some good concerns. Do you know why they need the unfilled pouches? You may be able to provide digital copies of the label if they're interested in labeling compliance issues. For package engineering, could you not provide blank, unprinted pouches if they needed to do integrity or barrier testing?

Agree, I wouldn't do it - unless, you put on your label "not for consumption". Or, you could officially sell EMPTY pouches (having invoice and other paperwork as a proof). However, on the other hand, how would you control your labeled containers (e.g. pouches) when they leave your facility? I mean, anyone could use it - say, even if it had product in it, it might be emptied and then used for whatever purpose.

Hi everyone!

Thanks a lot for your support & guide on these different paths.

Accordingly I have sent an explanation request from our customer to avoid disputes and nonconformities.

Thanks