Can we receive unlabeled bottled liquid marinades for Co-manufacturing

We are a spice/seasoning manufacturer. We have a co-manufacturer/labeler that sends us bottled liquid marinades.

Now we have around 2 different brands that are labeled on those bottles. In some cases, one brand sells more than the other. Management has asked me about this:

From a federal/regulation standpoint, Can we bring in those bottles unlabeled? And us to do the labeling? So we know how many of each brand to ship? Instead of one going unsold because that brand doesn’t sell? In my opinion it’s still the same as having it already labeled as long as we are not actually processing it (because it requires processing steps we don’t do here). Is it considered as a raw material since its unlabeled and supposedly needs to undergo some sort of process before it ships? I believe its not different but would like everyone’s opinion! Thanks!

I am not aware that a supplier is allowed to ship bottled product without a label. I would not personally allow it, even if there is a loophole somewhere. Your co-man could have accidentally sent you the wrong product (which has an allergen or incorrect ingredients), and you wouldn't know unless the marinades look radically different. 

This label though, is our label, but they label it for us. We have these labels in-house here. Its just they bottle AND label for us. Does that make sense?

Tracibility could be a nightmare.

I do see now and then companies that produce unlabeled items and sell them to supermarkets who in turn put their labels on it.

If you are under a standard such as SQF there are a number of requirements for contract manufacturers, but I am sure you know that already.

This label though, is our label, but they label it for us. We have these labels in-house here. Its just they bottle AND label for us. Does that make sense?

 Yep, it does make sense. I once worked for a company that did this. My thought might be to have them apply only a generic back panel (nutritional panel) with a lot code, then you can apply the front label yourself. That way the ingredient information is already applied, and should be able to ensure the product in the bottle actually is the right product.

I'm really not a big fan of unlabeled things, so this would be the only thing I would ever allow to happen.

SQF, how does someone justify unlabeled product being sent to supermarkets? Is there something to identify the product being shipped so the supermarket can label the items with the right label? Makes me wonder why there are so many allergen recalls for products being mislabeled....

 Yep, it does make sense. I once worked for a company that did this. My thought might be to have them apply only a generic back panel (nutritional panel) with a lot code, then you can apply the front label yourself. That way the ingredient information is already applied, and should be able to ensure the product in the bottle actually is the right product.

 

I'm really not a big fan of unlabeled things, so this would be the only thing I would ever allow to happen.

 

SQF, how does someone justify unlabeled product being sent to supermarkets? Is there something to identify the product being shipped so the supermarket can label the items with the right label? Makes me wonder why there are so many allergen recalls for products being mislabeled....

Now on the outside of the case that these bottles come in, have labels identifying what it is,, its only the bottles inside that have no label, what do you think? That way they are identifiable? 

Now on the outside of the case that these bottles come in, have labels identifying what it is,, its only the bottles inside that have no label, what do you think? That way they are identifiable? 

I wouldn't say it couldn't be done, but still I personally wouldn't allow it. Too much risk for me. Could they at least apply a lot code on the bottle lid that you can match up to a COA? 

I guess if a recall happened due to mislabeling, you could say that the supplier gave you a COA, and you received what you "thought" was the correct marinade. 

QAGB WROTE... SQF, how does someone justify unlabeled product being sent to supermarkets? Is there something to identify the product being shipped so the supermarket can label the items with the right label? Makes me wonder why there are so many allergen recalls for products being mislabeled....

The majority of this occurs with bulk packed bakery items such ad bagels, rolls, mini danishes with the store location determining counts per bag, tray, etc and then they apply their own custom labels. It actually works out well unless someone forgets to record the tracing barcode/number on the master carton.

That's pretty interesting. In cases like this, traceability and scanning information has to be very accurate. As long as your traceability processes are mostly electronic and you haven't had to establish corrective actions for traceability failures, this is a possibility.

Not really my cup of tea, but if it works well, I feel better about it. 

Hi TFS,

I don't see an issue as long as you can maintain product identity throughout the process: 

• Receiving: regulatory information is present on the outer case 
• Storing: unlabeled bottles remain in sealed cases until labeling
• Labeling: transferring lot numbers and doing a first product check to ensure you have the correct 

The last response is most sensible to me. As long as you maintain traceability and segregation of this item.

Say make a separate item number for this unlabeled bottled products so that when you receive it, it is received as a different item than the labeled products. Treat it as you would received a raw material and a bulk-packed product, which can get away with just an outer shipping case label.

Sometimes we tend to overthink and over complicate things...

Hi,

Jumping onto this conversation.  I have a similar issue.  I also work for a seasoning/spice manufacturer.  We have a couple customers that want us to bottle their spice blends but send it out unlabeled so that they can label it themselves.  The current idea is to label the box with all the information and put "not for retail sale" on it to ensure our liability.  However, I said we know that the customer is going to label it themselves and sell it so I don't see how putting "not for retail sale" really protects us.  

Other issue for me is traceability.  Current thought is to put a small sticker on the bottom of the bottles with code info.  However, I have no way of knowing what the customer will do once they receive the product.  Do we demand they keep our sticker?  Or are they accepting responsibility for trace at that point and if they want they can remove the sticker and add their own code?  Are we liable for traceability once it gets to the customer or is that where our liability ends?  

Hi,

 

Jumping onto this conversation.  I have a similar issue.  I also work for a seasoning/spice manufacturer.  We have a couple customers that want us to bottle their spice blends but send it out unlabeled so that they can label it themselves.  The current idea is to label the box with all the information and put "not for retail sale" on it to ensure our liability.  However, I said we know that the customer is going to label it themselves and sell it so I don't see how putting "not for retail sale" really protects us.  

 

Other issue for me is traceability.  Current thought is to put a small sticker on the bottom of the bottles with code info.  However, I have no way of knowing what the customer will do once they receive the product.  Do we demand they keep our sticker?  Or are they accepting responsibility for trace at that point and if they want they can remove the sticker and add their own code?  Are we liable for traceability once it gets to the customer or is that where our liability ends?  

I would think if let's say you were my bottle supplier, whenever we receive your bottles, we document the product code/lot code of that product upon receiving. Now when we label them we're going to be putting our label but keep your lot codes. because you really were the ones that manufactured the bottles, your processes all went into making the marinade. So when there is a recall, we trace the lot codes and back to you, you will then let us know all about what went on that day you made that product. Because you are also considered a supplier here and not only a co-manufacturer.  This is how I see and what we currently do. I hope it makes sense.