Just because your label says it must be cooked, doesn't remove you from any liabilities.
Take a look at prepared cookie dough. It says must be cooked/baked, do not eat raw cookie dough. Yet people have, and have sued and won.
The definition of a CCP is a step or process that prevents, eliminates, or reduces a hazard to an acceptable level. What are your potential hazards? Associated risks? Then ask: Does this process prevent, eliminate, or reduce the hazard(s) to an acceptable level? If yes, then I would say it's still a CCP.
We make pizzas and are USDA inspected. Our CCP is time & temperature control of the ingredients in process, even though the cooking step stated on the labels is essentially a kill step.Go to the full post