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.