We are an SQF certified facility for manufacturing of essential oils. Our HACCP plan covers all of our incoming oils, blending / distillation, packaging and labelling followed by distribution (1 PC and 1 CCP at filtration step). We would like to start reselling some of our products without filtering and packaging them (only opening to take a sample).
I would like some advice on how to incorporate this into my current HACCP plan. Do I treat the products for re-sale as an incomining RM (even though I have already done this since they are the same RMs as we use in our production) or do I treat this as a processing step? My last option would be to have a separate HACCP plan for reselling/distribution, but I am trying to keep it as simple as possible. My first thought is that I will have to apply a supply-chain preventive control to these products.
What are your thoughts?
Located in Canada but exporting into the US so FSMA does apply.