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Help! CofA Requirements?

COA CofA Import Repacking Re-packing Bulk

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#1 jd445

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Posted 13 March 2014 - 04:39 AM

Hi all,

 

I've got a new customer seeking a custom bulk packaged solution of an individual ingredient I'm importing from overseas (I'm in the U.S.) My international supplier provides a CoA with every shipment.

 

If I'm taking this product and repacking in a U.S. facility, am I correct in thinking that the only CofA I will need to provide my customer is one from the point of repacking in it's "final" packaging form (before it's used in the customer's recipe)?

 

If this is not the right topic area, please let me know!



#2 mesophile

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Posted 15 March 2014 - 10:09 AM

Good Afternoon,

 

The Certificate of Analysis from your supplier is only valid in the condition it is supplied in, e.g. the sealed un-opened packaging. As soon as you open this packaging and process the product in any way, even just to repack it, you will need to conduct further analysis on the re-packaged product your company has produced - as you said in its "final" packaging form. 

 

You still need to keep the CoA from your supplier as this acts as part of your supplier approval/due diligence systems though.

 

Thanks

 

Simon



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#3 jd445

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Posted 15 March 2014 - 01:26 PM

Thanks Simon! Some further clarification:

 

Is there any scenario where I need to provide the CoA from my supplier to my customer?

 

Should I be looking to produce a CoA at the point of repacking or one step further once the product is pressure pascalized? And obviously I'll have to send a sample to a 3rd party lab as part of that lot for analysis?



#4 jd445

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Posted 15 March 2014 - 05:49 PM

Also wondering if COAs produced at repackaging facilities are mandated to note the original manufacturer and/or place of manufacture?

For some context I'm trying to determine if it's possible to supply this customer without revealing who my supply partner is.



#5 Tony-C

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Posted 17 March 2014 - 05:23 AM

I would want to be checking the product myself rather than relying on a supplier's COA. As well as checking the incoming product I would be checking the repackaged product the ensure that there is no contamination during your process.

 

Depending on the product and risks when you have a history of performance it may be acceptable to supply a certificate of conformance and reduce the amount of testing you do to each incoming batch and periodic checks of final packed product.

 

Regards,

 

Tony







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