SQF - Destruction of Trademarked items

Hello everyone.  This is my first post, so I hope I get it right!

I am struggling with the Destruction of Trademarked items.  

We bottle water - private label.  We have over 400 different labels in house.   Currently overrun product is given to employees as "free" water to drink in the building.  Sometimes it is sold to employees for home use, or donated to the fire house, policy dept, local charities, schools and football games. 

The actual labels, when there is a revision change, or the customer stops buying etc are just thrown away.  

My question is

The labels need to be shredded and have a company do it to provide documentation correct?

But what about the bottled water?  After reading some things, I do not believe that is allowed without customer approval. 

My thought was to write and "agreement" and have customers choose to do one of the following

1.  Take all overruns

2.  Authorize release of water with their label to be donated to local charities

3.  Authrorize release of water with their label to be sold for home use only

Is any or all of this acceptable to get through the audit?  It is our first time going to SQF 

Bottled water plant here. Your private label destruction/donation procedure will depend on customer requirements more than SQF's. 

SQF really only cares if you deviate from your customer requirements, or if you destroy excess labels in a way that would allow counterfeit product to be produced, e.g. if you just tossed your entire rollstock of labels in the trash. They should be damaged in some way that would keep someone from stealing and labeling something random with a trademarked label.

Have a client that is a bottler and as a former SQF Auditor I did audit a number of bottled water plants.

One of the clients routinely gave overrun as donations to food banks - this was fine, however they left the private labels on them and sure enough a group of folks decided to make a complaint about the water to the the grocer that had their name on the donated water. The grocery chain did not know the bottling plant was giving away overruns with their label on and it became a very big issue.

The next issue is what happens in the event of a recall -- how do you track that water that you gave away from under the labels you gave it away as?

All of the bottling companies destroy old, outdated labeling and certify destruction in the event the customer may require it.

What I see is bottling companies continuing donations of water from overruns, but with either on overlay label or a by hand re-labeling indicating the water is a donation by so and so and not for resale.  This can then we easily wasted out and recorded so it does not impact a recall situation or for the most part a mock recall situation that an Auditor may demand.

SQFconsultant -  As far as trace ability, we still do our normal procedure and recording what bottles ship to which destination - so for example we just donated 2 pallets of water to the high school graduation a few months ago -  and it took a little work since it was a mixed pallet of multiple labels - but we recorded all the case codes and logged them.  Does this not suffice as far as trace ability?

Finally - most of our customers ( not all) have contracts that we have included a statement we may donate overruns if they do not take them at the time.  Is this sufficient you think?

Sounds like you're on it springs angel. We cut the whole rollstock with a sawzall so that they are damaged in a way that they wouldn't be used on a bottle, and torn off labels typically can't be reapplied without looking "sketch". Large stocks are sent directly to film recycler who certifies that the film was melted down/shredded.

If you couldn't reuse it in your own plant, it's probably safe from counterfeiting as is.

Donation for us counts as a retail outlet, so we would notify our donation outlets of any recalls and provide the information, but don't necessarily worry about reconciliation just like the grocery store doesn't go to your house to ask how much you bought and whether you destroyed it.

I think your customer contracts should be sufficient to demonstrate that you're destroying the material properly.

Have a client that is a bottler and as a former SQF Auditor I did audit a number of bottled water plants.

 

One of the clients routinely gave overrun as donations to food banks - this was fine, however they left the private labels on them and sure enough a group of folks decided to make a complaint about the water to the the grocer that had their name on the donated water. The grocery chain did not know the bottling plant was giving away overruns with their label on and it became a very big issue.

 

The next issue is what happens in the event of a recall -- how do you track that water that you gave away from under the labels you gave it away as?

 

All of the bottling companies destroy old, outdated labeling and certify destruction in the event the customer may require it.

 

What I see is bottling companies continuing donations of water from overruns, but with either on overlay label or a by hand re-labeling indicating the water is a donation by so and so and not for resale.  This can then we easily wasted out and recorded so it does not impact a recall situation or for the most part a mock recall situation that an Auditor may demand.

What specifically is "Certified Destruction"? I work at a Winery and we are trying to come up with a Policy to destroy excess or defective trademarked labels. Is this something we could do ourselves if we document it, or should we enlist a professional shredding company?