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#1 Silvialima

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Posted 15 December 2017 - 03:20 PM

Hello everyone!

 

Are you aware of any regulation that would prevent a warehouse from applying new labels for FDA products in a situation where the vendor guarantee additional shelf life? The new labels would come from the vendor; however, they would be applied in facility (warehouse) that it is not owned by the vendor.  I know relabeling is a big NO NO for USDA product since you need to be a USDA inspected facility to be able to do this. However, what about FDA items? 
 
Thank you!
 
 

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#2 FurFarmandFork

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Posted 15 December 2017 - 06:44 PM

I think if you are an inspected warehouse you could do this in FDA-land. especially if the labels come from the vendor. More problematic if the food is canned or acidified maybe.


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#3 Fishlady

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Posted 20 December 2017 - 09:56 PM

Under FDA rules there should be no regulatory reason why you could not apply new labels.  Just be aware that anyone who applies labels (whether they own the product or do it on behalf of another company) is responsible for ensuring that the labels are in compliance with applicable regulations.


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#4 Silvialima

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Posted 21 December 2017 - 01:55 PM

Thank you for the responses!

 

Fishlady: Do you have any link to the regulation or guidance that explains with more detail what you mentioned? I want to discuss that topic at work, and it would be helpful to have some material to go over. 

 

Thanks!

 

Silvia


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#5 Fishlady

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Posted 21 December 2017 - 04:29 PM

I am not finding the exact reference, but I have worked for companies that perform custom processing and/or apply labels that are designed by the customer, and I have been informed by FDA inspectors that if we apply the label, we are just as liable as the label owner.  I believe this may be related to the fact that FDA includes "labeling" in its definition of "processing" (see the definition of "manufacturing/processing" in 21 CFR 117.3).


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