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What standards should we comply with as a private label company?


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#1 Paula da Silva

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Posted 24 September 2018 - 01:36 PM

Hi!!

 

I was hoping you could help me with this....I'm getting very confused with requirements we should comply with as a private label company...

 

so a bit of background...

 

 

Our products (finished products sold to retailers or final consumer) are manufactured by contract manufacturers and sold under our brand name. Each of these co-manufacturers hold a GFSI certification, and we have written contracts and specifications agreed with them. We are in charge of the transport of the finished products from the manufacturing sites to our warehouse, and also in charge of the transport from the warehouse to some retailers.

 

I have 2 questions:

 

Having in mind the above, can we be certificated against the Agents&Brokers standards? I’m not sure if we would fall under any of these services and could apply this standard?

 

Do we need to have our own product recall procedure and HACCP if our co-manufacturers already have these? I'm so confused as we have some customers asking to have these and I'm not sure if we should send them the HACCP and product recall procedure from each of our co-manufacturers or ours?!

 

I hope I can get some advice from someone more experienced than me!...

 will be greatly appreciated !

thanks,

Paula

 

 

 



#2 SQFconsultant

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Posted 24 September 2018 - 02:30 PM

HI Paula,

 

You don't mention what scheme you are looking at getting certified under - I will use SQF as an example --

 

Since you say that you have a warehouse - and ask if you can be certified against the Agent & Broker category -- I would default to the SQF Food Safety Code for Storage and Distribution - this is food sector category 26 and Module 12 and 2 would apply.

 

If you just had an office that you work out of and not your own warehouse where you store food products that would be Agent/Broker.  However you have a DC and thus are subject to compliance with all food safety standards.

 

You would of course have to have you own recall plan that in many ways could technically piggyback your contractors plans, but you have to have procedures in place for the what if's.

 

We have several clients where they have contract manufacturers handling all of their stuff for them and each one has a full blown food safety management system and items to comply with those standards contained within Module 12 and 2.

 

Someone else would need to handle BRC, FSSC 22000, IFS and all the others as we specialize in SQF.

 

I imagine however it would be similar in nature.


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#3 Paula da Silva

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Posted 24 September 2018 - 03:02 PM

HI Paula,

 

You don't mention what scheme you are looking at getting certified under - I will use SQF as an example --

 

Since you say that you have a warehouse - and ask if you can be certified against the Agent & Broker category -- I would default to the SQF Food Safety Code for Storage and Distribution - this is food sector category 26 and Module 12 and 2 would apply.

 

If you just had an office that you work out of and not your own warehouse where you store food products that would be Agent/Broker.  However you have a DC and thus are subject to compliance with all food safety standards.

 

You would of course have to have you own recall plan that in many ways could technically piggyback your contractors plans, but you have to have procedures in place for the what if's.

 

We have several clients where they have contract manufacturers handling all of their stuff for them and each one has a full blown food safety management system and items to comply with those standards contained within Module 12 and 2.

 

Someone else would need to handle BRC, FSSC 22000, IFS and all the others as we specialize in SQF.

 

I imagine however it would be similar in nature.

Hi Glenn, thanks for your help!, sorry, you're right, I didn't mention the scheme- which is BRC -but like you said with SQF is similar.

 

I wasn't clear before, we use a third party warehouse and like you said we are office based (at the moment our contract manufacturers handle all for us), so with that in mind could we (brand owners) get certified against the Agent & Broker category?

 

is DC distribution centre/warehouse?

 

thanks for your help again!

Paula



#4 pHruit

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Posted 25 September 2018 - 08:42 AM

Hi Paula,

It sounds like BRC A&B should suit your activities quite well - from the current Issue 2 of the standard:

SCOPE

The Standard sets out the requirements for companies in the food, packaging and consumer products supply chain that buy, sell or facilitate the trade of products and may provide additional services such as the purchase, importation or distribution of the products, but do not manufacture or process those products

 

For the BRC certification you will most definitely require your own recall procedure, and the standard requires a "Product Safety Plan" based on hazard and risk analysis that is basically HACCP (and indeed it refers to HACCP principles as an example of the approach expected), but this applies to the activities of your business and subcontractors (e.g. transport and warehousing etc,) rather than the actual manufacturing. The latter is more likely to be covered as a prerequisite via your supplier approval process, but you'd need to consider this as part of the hazard analysis process.

 

In terms of the questions from your customers, I'd guess they are asking for HACCP documents relating to the actual manufacturing process but it's probably worth talking this through with them to understand what they actually want. We've been Agents & Brokers certified since Issue 1 first came out in 2015 and no customer has ever asked to see a copy of our HACCP for this, but lots of them want to see process flows for the actual manufacturing sites!

 

The recall procedure is more likely to be referring to your procedure as their suppliers, since it is your business with whom they will be dealing. Whether you want to share this publicly is something you may wish to consider within your business - it is a necessity for BRC certification so once certified you can refer your customers to this as evidence for its existence. Depending on the nature of the procedure it may contain information that you do not feel is appropriate to release externally (if nothing else, there may be personal details to contact key staff members out of hours, and this could fall within the scope of GDPR regs...) so you may find it easier to simply issue a statement confirming that you have the procedure, it's covered as part of your BRC certification, it's tested annually (again a BRC requirement) etc.

 

 

 



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#5 Paula da Silva

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Posted 25 September 2018 - 12:42 PM

Hi Paula,

It sounds like BRC A&B should suit your activities quite well - from the current Issue 2 of the standard:

 

For the BRC certification you will most definitely require your own recall procedure, and the standard requires a "Product Safety Plan" based on hazard and risk analysis that is basically HACCP (and indeed it refers to HACCP principles as an example of the approach expected), but this applies to the activities of your business and subcontractors (e.g. transport and warehousing etc,) rather than the actual manufacturing. The latter is more likely to be covered as a prerequisite via your supplier approval process, but you'd need to consider this as part of the hazard analysis process.

 

In terms of the questions from your customers, I'd guess they are asking for HACCP documents relating to the actual manufacturing process but it's probably worth talking this through with them to understand what they actually want. We've been Agents & Brokers certified since Issue 1 first came out in 2015 and no customer has ever asked to see a copy of our HACCP for this, but lots of them want to see process flows for the actual manufacturing sites!

 

The recall procedure is more likely to be referring to your procedure as their suppliers, since it is your business with whom they will be dealing. Whether you want to share this publicly is something you may wish to consider within your business - it is a necessity for BRC certification so once certified you can refer your customers to this as evidence for its existence. Depending on the nature of the procedure it may contain information that you do not feel is appropriate to release externally (if nothing else, there may be personal details to contact key staff members out of hours, and this could fall within the scope of GDPR regs...) so you may find it easier to simply issue a statement confirming that you have the procedure, it's covered as part of your BRC certification, it's tested annually (again a BRC requirement) etc.

thanks so much this, it really helped me to clarify all the (confusing) ideas I had in my mind!

 

What are the benefits of getting certified against BRC A&B when all/majority of customers are happy if our manufacturers hold a GFSI certification?

 

Is there any product recall procedure for A&B you can share? I couldn't find any in the forum specific to A&B

 

thanks again!

Paula



#6 pHruit

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Posted 25 September 2018 - 01:08 PM

Hi Paula,

If you're handling branded products then you are in the slightly privileged position of escaping the most demanding bits of the retailers' requirements - for those of us supplying ingredients for own-label, it's now mandatory for supply to the manufacturers for many of the supermarkets, and also now for a growing number of brands. The Elliott Review into the Horsegate fiasco didn't reflect too well on agents (deservedly so, in the case of those involved in this), and it triggered a great deal more scrutiny of agents in general. I could potentially see this expanding to start covering branded product at some point, so it wouldn't hurt to be ahead of the curve on it.
However, the main benefit for you is that it will help you implement and structure formalised systems for lots of areas that are relevant to the managing the quality and safety of your products and related business activities.

If you don't actually need the certification there would be nothing to stop you buying a copy of the standard (available from the BRC Bookshop here: https://www.brcbooks...okers/c-24/c-73) and just using it as a guide to set up the systems for yourselves, without going through the certification process for now - exactly what new development this would require will depend to a large extent on what systems you currently have in place, but if implemented sensibly it should help provide some structure for implementing some things that may genuinely be beneficial (e.g. the recall procedure) and will also give you a significant head start if you find you do need to pursue certification at some future point.

 

In terms of the recall procedure, unfortunately this is a document that I'm not allowed to release outside the confines of our offices. Nonetheless, a recall procedure for any of the food safety standards should suffice as a basic template for you to adapt, so if there are others you've seen then they'd probably work as a starter - broadly the goal of tracing and reconciling the affected stock and managing relevant communication and notification is still the same.



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#7 Paula da Silva

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Posted 25 September 2018 - 01:54 PM

Hi Paula,

If you're handling branded products then you are in the slightly privileged position of escaping the most demanding bits of the retailers' requirements - for those of us supplying ingredients for own-label, it's now mandatory for supply to the manufacturers for many of the supermarkets, and also now for a growing number of brands. The Elliott Review into the Horsegate fiasco didn't reflect too well on agents (deservedly so, in the case of those involved in this), and it triggered a great deal more scrutiny of agents in general. I could potentially see this expanding to start covering branded product at some point, so it wouldn't hurt to be ahead of the curve on it.
However, the main benefit for you is that it will help you implement and structure formalised systems for lots of areas that are relevant to the managing the quality and safety of your products and related business activities.

If you don't actually need the certification there would be nothing to stop you buying a copy of the standard (available from the BRC Bookshop here: https://www.brcbooks...okers/c-24/c-73) and just using it as a guide to set up the systems for yourselves, without going through the certification process for now - exactly what new development this would require will depend to a large extent on what systems you currently have in place, but if implemented sensibly it should help provide some structure for implementing some things that may genuinely be beneficial (e.g. the recall procedure) and will also give you a significant head start if you find you do need to pursue certification at some future point.

 

In terms of the recall procedure, unfortunately this is a document that I'm not allowed to release outside the confines of our offices. Nonetheless, a recall procedure for any of the food safety standards should suffice as a basic template for you to adapt, so if there are others you've seen then they'd probably work as a starter - broadly the goal of tracing and reconciling the affected stock and managing relevant communication and notification is still the same.

 

Thanks so much for sharing your knowledge and insight on this ! I really appreciate it, I'm definitely starting on working with the BRC guidelines in case we need to get the certification in the future, thanks :spoton:!!



#8 Paula da Silva

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Posted 26 September 2018 - 12:54 PM

 

DO you mind clarifying what you mean with it's now mandatory for supply to the manufacturers for manu of the supermarkets? do you mean that you as an ingredient supplier need to have the A&B certification in order to supply your ingredients to manufactureres that produce for retailers? sorry I'm slightly confused with this :S



#9 pHruit

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Posted 26 September 2018 - 01:19 PM

Hi Paula,
Apologies, I could have structured those sentences a little better!
We supply ingredients to brands and to the retail co-packers, and in general many of the latter now mandate BRC A&B certification as a requirement for supply.



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