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Responsibilities for copacker exporting customers product to USA

FSMA Process Filing

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Scampi

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Posted 25 January 2019 - 02:40 PM

Hello all

 

I've exported to the US when I worked in meat which was very straightforward. Now we have a copacking request and I would like to make sure I've at least looked as what's really required so we're A) in compliance and B) incorporate it into our costs.

 

We are an acidified food producer (no longer applies in Canada) so my questions are

 

Do I have to file my process even though we're not exporting our "own" product---buyer would own the product once they pick up at our dock?

 

Must I register our company even though we won't "own" the product

 

And any other tidbits I ought to be aware of

 

Thanks a million


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Scampi

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Posted 28 January 2019 - 01:27 PM

No one has any words of wisdom???


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kfromNE

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Posted 28 January 2019 - 05:01 PM

An FYI: not sure but for some reason I noticed your first post never popped up under the 'view unreplied topics' tab. Maybe it was just mine that that happened too. Though if it happened for everyone - people might not have noticed your question. Wish I could help answer your question, but not my area of expertise.



Scampi

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Posted 28 January 2019 - 05:50 PM

Thanks KofIA I will pass that one to Simon!!!


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Drumstick

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Posted 29 January 2019 - 07:00 AM

Hi Scampi,

When you say "copacking", you mean that you're packaging someone else product? (Sorry, language barrier). If that's so, I read a couple of years ago that the last food operator in the "supply chain" before exporting to the U.S. must be register within the FDA , unless this operator just does "de minimis" operations; the cfr gives some examples of "de minimis" processes, but packaging is not one of them, so you probably need to register (and therefore be "inspectionable", if that word exists). Years ago my company sent their product to another company to package the product right before exporting, and they had to be register.

I don't have right now the link to the cfr chapter where it says so, and I don't know if there are exemptions for certain products (I think this is the same for every food product), but I could share it later if that's the información you're looking for...just let me know :).



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Scampi

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Posted 29 January 2019 - 02:19 PM

Thanks Drumstick; that's what I suspected. 


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