Allergen Registry (SQF)

The SQF code requires a manufacturer to have a registry of all allergens applicable in the country of manufacture and country(ies) of destination.

I am confused by what SQF considers to be the country of destination. Is the customer we ship product directly to considered the country of destination, or the consumer who receives the product from our direct customer?

We manufacture product in the US and bulk pack it for customers located in Canada. These customers then re-pack the product into individual units and then sell the product to consumers located all over the world. 

So.. If we manufacture product in the US and then ship it to our customers warehouse in Canada we would have to control allergens regulated both by the FDA and the CFIA. The customer may then sell the product in retail stores located throughout the US, Canada and the European Union. 

In this scenario would our Allergen Control program have to account for allergens that are regulated in the EU?

Our customers have not specified what countries they plan to sell the product in and do not specify what allergens they require us to declare.

For our customers who make us aware that they will be exporting, we have contracts in place that require us to fully disclose all information regarding allergens (US + EU) and GMOs for their products. We are responsible to control for EU allergens for THEIR ingredients and batches (but not for other customers who do not export). 

We have two separate allergen and sensitivity registries--US and EU.

The customer is responsible for labeling regulations in any destination country (other than domestic) once it leaves our dock.

It's a tricky dance and must be implemented carefully, but it works and has passed audits.

Your product has to meet the laws of any country where the product is sold.

The matrix I use for an allergen register has the country on top and the allergen listed on the left side.  I then put a check mark in the box if the allergen is addressed by a certain country or set of countries.

There is another column to indicate whether the allergen is present in the plant and where it is located:  vending machines, ingredients, etc.