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Responsibilities for meeting Country Specific Regulations

International Shipping

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#1 jportz

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Posted 18 August 2014 - 01:06 PM

Do we have to know what country our customers ship to if they further manufacture the products we produce.  Would we have to state that and ensure the regulations for that country are followed for example Allergens?


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#2 Charles.C

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Posted 18 August 2014 - 02:01 PM

Do we have to know what country our customers ship to if they further manufacture the products we produce.  Would we have to state that and ensure the regulations for that country are followed for example Allergens?

 

Dear jportz,

 

Offhand, only if you are about to take a screening test for potential telepaths. :smile:

 

However there has recently been an extended discussion here regarding respnsibilities of suppliers of product to be commercialised within same country. This related to a situation where "due diligence" might be considered insufficiently exercised by the producer. But it's often not simple black/white decisions.

 

IMO yr query might depend on the specific circumstances, eg location, potential hazard, type of product, brand involvement, consumer type etc.

 

More detail possible ? :smile:

 

Rgds / Charles.C


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Kind Regards,

 

Charles.C


#3 jportz

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Posted 18 August 2014 - 02:09 PM

Our old HACCP Coordinator has listed in our company history that we ship to Europe and Japan.  We don't ship to these countries but, some of our customers might.  Do we have to know where they are shipping to and make our policies follow their regulations for Allergens.  Europe I believe has Celery as an Allergen but, we don't ship there.  Our customers might though. Does Celery have to be on our list of allergens?  I hope this makes sense.


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#4 Charles.C

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Posted 18 August 2014 - 03:28 PM

Our old HACCP Coordinator has listed in our company history that we ship to Europe and Japan.  We don't ship to these countries but, some of our customers might.  Do we have to know where they are shipping to and make our policies follow their regulations for Allergens.  Europe I believe has Celery as an Allergen but, we don't ship there.  Our customers might though. Does Celery have to be on our list of allergens?  I hope this makes sense.

Dear jportz,

 

I guess this is essentially another labelling query.? :smile:

 

IMEX of export, the approval step for labelling responsibility is on the buyer, regardless of statements in a  mutually agreed Product Spec.like “labelling as per legislatory requirements at destination”. And IMEX of top companies, their QA rep. will go over the ingredients/yr data with a fine-tooth comb. It's even more interesting when the producer cannot read the label.! And sometimes it still ends up in a  far place with a white sticker on it in yet another language. :smile:

 

IMO it's easiest to make the Policy completely generic over current item, ie non-specific. Like the Product Spec. :smile: (can always add a nice allergen vs country matrix somewhere else for show).

 

The actual approval process is IMEX documented separately, eg in a Procedural SOP, but i suppose it could be in the Policy if  so desired.

 

However  every country seems to have its own interpretive quirks in this area so it’s ultimately a US question and i won’t be surprised if some strange exception(s) pops up. One possible protection in previous thread for UK was liability insurance, at a cost of course.

 

Some of US posters here are surely exporting ?

 

Rgds / Charles.C


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Kind Regards,

 

Charles.C





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