4 replies to this topic

[classic]

Small amounts of product that our company produces are supplied to customers who then export them.  We do not direct export ourselves.

 

This whole area is new to me.

 

Please could anyone advise how we can comply with  BRC 1.1.6 as regards to 'relevant legislation applicable to the country in which the product is sold' and 5.1.5. ' all products shall be labelled to meet legal requirements for the designated country of use'

 

Also is selling products within the EU classed as exporting? 

 

Any help greatly appreciated.

[Simon]

Can anybody help with this?

[Tony-C]

Small amounts of product that our company produces are supplied to customers who then export them.  We do not direct export ourselves.

 

This whole area is new to me.

 

Please could anyone advise how we can comply with  BRC 1.1.6 as regards to 'relevant legislation applicable to the country in which the product is sold' and 5.1.5. ' all products shall be labelled to meet legal requirements for the designated country of use'

 

Also is selling products within the EU classed as exporting? 

 

Any help greatly appreciated.

 

Hi Classic,

 

This is not unusual, for instance manufacturers supplying retailers in the UK who have stores outside the UK (Re. 5.1.5 In some cases I have seen 'over labels' applied in the relevant language).

 

You should find out where the customer is exporting the products to as it would fall under 'reasonably expected countries of sale'.

 

If it is the EU I would still regard it as exporting but if you quote & comply with relevant EU legislation that should be sufficient.

 

This won't be a new thing to BRC and it may be something you can discuss with your certification body but I suggest you find out in which countries products are being sold first.

 

Regards,

 

Tony

[Charles.C]

Dear classic,

 

I have one question - Since the situation appears to be ongoing, how do you currently decide on the required labelling, etc, eg who approves it ?

 

IMEX, it is typically the responsibility of your immediate customer to solve such problems for you, eg to organise approval of labels on yr behalf or provide the appropriate external contact capable of approval on your customer's behalf.

 

IMO you are not expected to be telepathic or familiar with every global legislation. A similar situation presumably exists where an external final receiver is directly involved with yourself. ?

 

I would anticipate that BRC  are also familiar with such a "route".

 

Rgds / Charles.C

[classic]

The products involved have been up to now for Food Service rather than retail.   The companies that buy our products and then export them are either based in the UK or in Europe and then supply them to countries such as Cyrpus and other ex pat areas .  I believe it is the company who export that decides on the labelling if necessary and overlabels the information on the product.  The products involved have minimal labelling as they are going into Food Service.