No direct experience with fresh fruit produce but generically the answer to yr query is typically via a risk assessment from auditorial POVs.
IMEX of other fresh inputs, COAs are often a non-existent dream. And usually auditors will be equally aware of this.
As per a parallel current thread, many locations have no familiarity/belief in letters of guarantee however I anticipate a mutually agreed/signed specification would be regarded as equivalent for audit purposes. The latter is often regarded as the minimal acceptable requirement IMEX (non-SQF)
Many companies categorise their inputs into high/low risk based on theory/literature/experience and write control procedures accordingly.
Generically, i expect that fresh fruit produce is regarded as low risk (eg can refer to the appropriate SQF module's page tabulating associated status factors) but there are several recent examples of microbiological exceptions occurring which have somewhat tightened the situation. As a result and depending on product/process, it may be a case-by-case situation.
GAP systems are one common pre-harvest gate option for fresh produce control.
Rgds / Charles.C