Producer responsibilities when customer freezes product and sells it?

Advice needed.  If a customer choses to freeze a product once it has left a production site and then sell it on frozen, what responsibility does the original manufacturer have regarding verfying and validating the shelf life of the product.  Sorry I am unable to give you product details as I don't wish to identify the company involved.  The original product is packed into MAP with a 3 week shelf life and requires chilled storage.

I'm not sure if this helps given the information you have provided but you will have a responsiblity within your HACCP scope to identify the customer and/or consumer groups that will be using the products you manufacture.  As part of that you would then have a responsiblity to validate recommended storage conditions and associated shelf life.  This would be transferred to a specification that you are supplying your customer to ensure they have all the information they require.  If the product is MAP sealed is it therefore pre-packed and into printed packaging?  Are they therefore disregarding the storage conditions on the packaging and over labelling the date code information?  That would be a worry! 

I think if you are concerned the simple thing would be to set up a small shelf life test and forward the results to them with your recommendations. 

Do you think the quality of the product is going to deteriorate? Is that your concern?

Dear classic,

 

Lack of details in yr OP limits specific comments.

 

It might be beneficial if yr FSMS system, including the relevant product as originally processed/labeled, are certified, eg to BRC.

 

Regarding labeling aspects, this (2011) document (current validity unknown) may be of some interest in respect to responsibilities. For example, Pt1 ( 13,16,17), FAQ (14c,19).

 

guidance on the application of date labels to food, Defra, 2011.pdf   295.54KB   18 downloads

 

Rgds / Charles.C

Thanks To clarify the product is labelled with the correct date at the producer site to include the freezing process. The company who freezes it does not change the labelling as that is the proroducer site responsibiliy. What appears to be missing is the original work where the shelf life was established. That was the reason for the question. Appologies if this was misleading. Any ideas how a shelf life trial could be set up without having to wait for 12 months for the results

I have a similar issue where i supply to a customer who then freezes the product, to defrost and subsequently sell on to the consumer.

 

I have shelf life validation for the chilled product, and i have challenged the customer for a copy of the shelf life validation of the frozen product, for my records, in the event of an EHO complaint. He has refused. I don't even know how he has frozen his product. Is it blast frozen or just left in a conventional freezer? For my own peace of mind, i have conducted a small shelf life trial using both methods. I think that what you call covering my arse!

 

We supply the product with a juilan code and no best before. we even sleeve it, but we are still not required, by his instruction, not to add a best before.

 

I wonder if he can actually trace his product??

 

Caz x

Classic, if the production site is labelling the product with a frozen Best Before Date then it is surely their responsibility to validate this shelf life? Does the customer who freezes the product have any frozen samples you could use for shelf life analysis at a laboratory?