I am aware that there have been numerous posts on shelf life. This is not about the finer points of the types of shelf life, I would like to ask about potential consequences of shelf life decisions.
Our company manufactures a mineral food ingredient. We have assigned it a "best use by date" (BUBD) of 1 year. The product may lose some efficacy after one year, but not much and the loss is entirely dependent on storage conditions, and the product is a mineral based product so its not spoiling or becoming toxic. It should technically be effective long past 1 year, if stored properly, we just don't have supporting data.
We, of course have, many customers coming back to us to issue a shelf life extension. We are uncomfortable with this decision because the product has been outside our chain of custody. However, some in our organization think we can test the product for efficacy for our customers and let them make the decision as to its usability. However, this does not appear to extend a food safety guarantee.
Others (including myself) are uncomfortable with this suggestion, since the test implies quality, but not safety. If a recall or auditable event were to occur with our customer, and this practice was examined though I am not sure what the consequences would be. I would almost rather offer a firm extension or simply state we do not recertify and we do not test.
On the other hand it's a BUBD, not an expiration date, so the liability seems less of a concern, but then why ask for an extension?
So my question: What do you think are the consequences of retesting but not recertifying a product with a best use by date? Are we opening ourselves up to more liability or does it just not matter since we have a BUBD? What would a food safety auditor think if they saw a product past a BUBD but with a quality test? We would like to adopt best practice in this case.
Thanks in advance.