Relabelling (over original labels) and reusing repack boxes

Good Morning/Afternoon,
 
We are in the process of becoming SQF certified at our Storage and Distribution center which repacks many items and then reuses the empty boxes. My biggest issue is that they do not remove the prior label and sometimes it shows underneath the new label or the new label peels.
 
My first question is should they be required to remove the original label prior to shipping? Could this be a liability if the new label peels off?
 
My second question is we are dealing with multiple allergens so is it acceptable to repack an item into a box that previously contained a different allergen? For example repacking cottage cheese in a box that had tuna.
 
All items being repacked are sealed with no open food contact.
 
I want to apologize in advance if there is already any threads already available on this topic I looked but could not find the specific answer I was referring to. This topic has been bothering me ever since we started moving forward with wanting to become SQF certified.
 
Thank you everyone for your time and feedback!
 
I appreciate every one of you!!!
 
Sincerely,
 
Chris

I would have ALL old labeling removed..............it isn't necessarily a requirement, but it is inviting trouble with your customers at receipt. Yes, if the new label peels off, you now have a mis-labelled product and it is a liability.

 

If you are only repacking sealed containers into boxes that are completely intact, I think you should be fine as your not repacking the retail containers. Obviously if something has leaked or the carton is damaged, it should not be reused.

Chris,

 

The labels removed are the original product/manufacture labels or is it some of your company's secondary shipping label? if they are just your facility's labels, while the original product labels are intact, it can work to remove the labels and place a new one.

 

However, if these are original product labels, it can create a (bigger) traceability issues on your end. Usually, in a storage and distribution setting, containers are sold as a bulk units/multi packs and the original box label contains all the necessary information.

Wow. Is this a mom and pop operation? How do handle recall and traceability?

Hi Chris,

 

I regret to echo previous Post.

 

Don't know about USA but label "tampering" can generate an instant lot rejection in EC.

 

I suggest you involve some appropriate, technically knowledgeable/experienced personnel asap.

It's just bad practice to not remove old labels, for lots of reasons, not the least of which is FIFO issues that could arise and the facility is left with expired product because the new label came off and they are looking at the original label which is A) different product that it's contents and B) has a different BB date

Echoing everyone else... this sounds like a traceability nightmare. 

I disagree with repacking in boxes with different allergen matrices - if your label peels off, you have a potential labeling violation on your end.  Also - how do you know what the packaging has been exposed to at the initial manufacturing facility, especially if that facility only deals with one type of allergen? 

Thanks everyone for your responses!!! This group is great and I have learned a lot from you over the past several years!!! 

 

I agree that we should be minimally be removing the original label if we want to reuse the original box but the more I think about it and from reading your comments it sounds as though we need to discard the old boxes and start fresh to eliminate mislabeling and allergen cross-contamination.

 

Thanks again!

 

Chris