Our old HACCP Coordinator has listed in our company history that we ship to Europe and Japan. We don't ship to these countries but, some of our customers might. Do we have to know where they are shipping to and make our policies follow their regulations for Allergens. Europe I believe has Celery as an Allergen but, we don't ship there. Our customers might though. Does Celery have to be on our list of allergens? I hope this makes sense.
Dear jportz,
I guess this is essentially another labelling query.? 
IMEX of export, the approval step for labelling responsibility is on the buyer, regardless of statements in a mutually agreed Product Spec.like “labelling as per legislatory requirements at destination”. And IMEX of top companies, their QA rep. will go over the ingredients/yr data with a fine-tooth comb. It's even more interesting when the producer cannot read the label.! And sometimes it still ends up in a far place with a white sticker on it in yet another language.
IMO it's easiest to make the Policy completely generic over current item, ie non-specific. Like the Product Spec. (can always add a nice allergen vs country matrix somewhere else for show).
The actual approval process is IMEX documented separately, eg in a Procedural SOP, but i suppose it could be in the Policy if so desired.
However every country seems to have its own interpretive quirks in this area so it’s ultimately a US question and i won’t be surprised if some strange exception(s) pops up. One possible protection in previous thread for UK was liability insurance, at a cost of course.
Some of US posters here are surely exporting ?
Rgds / Charles.C
