Provenance Claims - section 5.4.4.

Please let me know how this is interpreted, I have read the interpretation guide as well and still not clear.

5.4.4 says

"Where products are labeled or claims are made on finished packs which are dependent on a status of a raw material including:

-specific provenance or origin

...

...

..."

We have always gone through audits saying that we do not have any product claims. We don't have gluten free, don't claim anything like low fat, or GMO free statuses.

However, lately a teammember raised a good point about ingredient declaration.

If we declare an ingredient, for example, Belgian chocolate. Does this fall under the "specific provenance" category? Is this considered a product claim??

Because then we need to do a mass balance every 6 months to meet this requirement.

I don't know it, but you state 5.4.4 "specific provenance or origin"

If you state "Belgium" then you need to prove origin.  Maybe.

Hopefully a BRC Food user will confirm one way or another.

Regards,

Simon

Belgian chocolate would come under this definition. We've just completed our first BRC Agents & Brokers audit (4 minors since you asked), and the auditor pushed in IP, asking us how we justified Sicilian Lemon. Fortunately, we were able to show the farms that supplied the processor and that they were in Sicily. You will need to show that you have a procedure that follows the guidelines as well as internal audits and traceability & mass balances to back it up.

Belgian chocolate would come under this definition. We've just completed our first BRC Agents & Brokers audit (4 minors since you asked), and the auditor pushed in IP, asking us how we justified Sicilian Lemon. Fortunately, we were able to show the farms that supplied the processor and that they were in Sicily. You will need to show that you have a procedure that follows the guidelines as well as internal audits and traceability & mass balances to back it up.

Thank you for the feedback from your audit!

The supplier we get Belgian Chocolate from is not from Belgium... can we call this a "style" of chocolate? If you know what I mean?

Hi Jtang

What would matter is where the chocolate is made, not where the supplier is.

If the chocolate is manufactured in Belgium and shipped to Canada by an agent, its still Belgian chocolate.

All you need are the procedures and documentation to back up the claim, of course 'all you need' is a relative term depending on the supplier or agent

rgds