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SQF FDA Beverages Expiration date

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#1 springsangel

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Posted 08 October 2019 - 08:07 PM

Hello everyone.   Are company has been asked to make a product for a customer with a quick turn around.  ( We are a water bottling and beverage plant, with SQF certification

I can obtain the ingredients (tea & Pectin) from an Approved Reputable Supplier.   However, for all of our products, we did shelf life testing to determine the expiration date, or use by or best by date.  We do not have time to do that for this customer. 

 

How do we determine the date to put on the bottle, the ingredient supplier, will NOT provide one.  All they will say is their product has a 6 month and 12 month shelf life.  Meaning the dry ingredients.  

 

The SQF code says you have to use scientific evidence. 

 

Can anyone point me in a direction?  I have google searched for 2 days, and everyone here is in a disagreement on how to proceed. 

 

 



#2 Ryan M.

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Posted 08 October 2019 - 11:45 PM

Are the ingredients in this product similar to other beverages you make? If so, you can use that as a reference.  I'm assuming it will undergo the same processing?



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#3 springsangel

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Posted 09 October 2019 - 09:06 AM

Are the ingredients in this product similar to other beverages you make? If so, you can use that as a reference.  I'm assuming it will undergo the same processing?

Everything is very similar, except we are not using corn syrup, we are using pectin.  This will be our first time using the pectin. 



#4 pHruit

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Posted 09 October 2019 - 09:42 AM

How are you processing/packing the drink?
Is it an ambient stable product? If so, you've probably already got process data to satisfy a "scientific evidence" requirement that the shelf life is limited by organoleptic factors (and is thus a "best by" rather than "use by" date)? (N.B. I'm not so familiar with SQF, but this would satisfy BRC requirements in this respect).



#5 springsangel

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Posted 09 October 2019 - 11:36 AM

How are you processing/packing the drink?
Is it an ambient stable product? If so, you've probably already got process data to satisfy a "scientific evidence" requirement that the shelf life is limited by organoleptic factors (and is thus a "best by" rather than "use by" date)? (N.B. I'm not so familiar with SQF, but this would satisfy BRC requirements in this respect).

It is ambient stable.  We always use Best Buy for our beverages.  Generally they will taste bad long before they actually are not usuable. 



#6 pHruit

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Posted 09 October 2019 - 01:54 PM

In that case I'd refer to the data supporting the ambient life as the scientific evidence.

Ryan M's suggestion of using other products as a reference / starting point is very sensible. You may also want to discuss with the brand owner / customer for whom you're packing the product, as they may already have data on similar products of theirs (although caution is needed due to potential differences in packaging types, processing etc).

Otherwise I'd take whatever seems to be the most similar product as your starting point as the factors that drive the ageing will be largely the same - O2 permeability of packaging, volatility of flavour elements, light transmission of packaging, propensity to oxidise etc. Replacing HFCS with pectin will have some effect on aw etc but it doesn't sound as though this is particularly relevant in the context of the shelf life.



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#7 Ryan M.

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Posted 09 October 2019 - 07:50 PM

Everything is very similar, except we are not using corn syrup, we are using pectin.  This will be our first time using the pectin. 

 

If that's the case then you should evaluate a change without using corn syrup and using pectin in the product will impact shelf-life.  As pH said your water activity will probably change, but will that affect the shelf-life?  Unlikely.

 

Look for affects of matrix stability and viscosity to be the primary factors with that difference.  If that's the case, how does it really impact the shelf-life?  Or, potential shelf-life?  If the customer is expected to shake or mix up the beverage before drinking then probably no effect, but if it will sit for a while on the shelf without moving you may see settling or layering of ingredients (potentially).

 

Whatever is decided with the shelf-life I would see if you can be conservative.  If it is decided you can put up to 100 days on the product, maybe cut it back 20% and see how it really holds up in the shelf-life based on your samples and testing over the shelf-life of the product.



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#8 Charles.C

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Posted 09 October 2019 - 09:06 PM

Beverages not my area and I  appreciate that this thread is attempting to offer  intuitive/semi-quantitative procedures to predict the shelf life of a "new" product".

 

However  I'm a little unsure as to whether the speculations discussed would be acceptable within the scope of (necessary?) "Validation" ?  Unless there is a specific documented support available ?

 

A question of (minimum) operational data ?


Kind Regards,

 

Charles.C


#9 Ryan M.

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Posted 10 October 2019 - 12:47 AM

Beverages not my area and I  appreciate that this thread is attempting to offer  intuitive/semi-quantitative procedures to predict the shelf life of a "new" product".

 

However  I'm a little unsure as to whether the speculations discussed would be acceptable within the scope of (necessary?) "Validation" ?  Unless there is a specific documented support available ?

 

A question of (minimum) operational data ?

 

For a new process, new facility, or novel product surely this would be needed.  However, with the OP's query it is not a new process, new facility, or novel product.  One can use the data and information from previous products, or current products using the same process to validate their shelf-life.  This is quite common in the beverage industry since so many new products can be formulated with a few ingredient changes.



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#10 Charles.C

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Posted 10 October 2019 - 05:20 AM

For a new process, new facility, or novel product surely this would be needed.  However, with the OP's query it is not a new process, new facility, or novel product.  One can use the data and information from previous products, or current products using the same process to validate their shelf-life.  This is quite common in the beverage industry since so many new products can be formulated with a few ingredient changes.

 

Hi Ryan,

 

I agree with you that IMEX FS Standards (and auditors) tend to allow substantial "wiggle-room" regarding choice of shelf-lives, particularly for raw/BB.

 

However, and just as one example, BRC's (general) opinion is -

 

The company must establish a documented procedure detailing how initial shelf-life trials are undertaken for new products and changes to existing products

(There is a potential exception in the Standard where initial trials are <<impractical>>, eg long-life. In latter case a documented, science-based, validation for the choice is mandated).

 

TBH I had (conservatively) interpreted yr Post 7 as suggesting an opposite view to that expressed in Post 9. :smile:

 

PS - SQF Guidance has  -

 

 The supplier must have a procedure in place to ensure the safety of products escalated from bench/pilot scale production to full commercial production.  This will include a food safety plan for new or revised products, shelf-life trials and validation, label declarations, allergen cross-contact trials, raw material, ingredient and packaging trials.
This applies to new products, changes to existing products and introduction of new materials or pack sizes.

This is not a mandatory element as not all facilities are involved in product changes or new product introductions.  However any SQF certified site that does introduce new products, packages or product revisions must have a documented procedure in place and implemented.

 

(One potential "semi-wiggle" in above is that afaik, safety  of OP's product is here not a factor)

(and sometimes "will" does not mean "shall").


Kind Regards,

 

Charles.C


#11 pHruit

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Posted 10 October 2019 - 08:06 AM

For a new process, new facility, or novel product surely this would be needed.  However, with the OP's query it is not a new process, new facility, or novel product.  One can use the data and information from previous products, or current products using the same process to validate their shelf-life.  This is quite common in the beverage industry since so many new products can be formulated with a few ingredient changes.

 

This has very much been my experience, and generally the auditors with the relevant scope approval to be auditing such facilities will have a reasonable understanding of the same principles. It's a bit reminiscent of the thread a few weeks ago that was discussing the pitfalls/merits of interpretation in the auditing of a standard ;)

 

I can't speak for the US market, but it is certainly not that uncommon in the EU/UK for "best by" ("best before" for the UK) dated ambient-stable beverages, i.e. those for which shelf life and indeed general microbiological stability isn't a limiting factor, to have a shelf life set based to an extent on supply chain operational requirements and realistically exceeding the duration for which the product is actually at its best. A longer life helps meet demanding minimum life on delivery requirements set by retailers and helps at the consumer end as people think they are buying a fresher product if they see it still has e.g. 18 months left.

In practice a lot of these products don't actually last that long, and will taste, smell and/or look rather tired some way before the actual date. For example I'd strongly recommend against drinking any canned beer from certain large brands anywhere near the stated best before date ;)

It's virtually never a problem in practice as the stock is sold through and used long before it reaches end of life, but there is typically an allowance made by the businesses to accept/expect a small number of quality complaints from consumers who have had the misfortune drinking something near the BBE.

 

We have a few brands for whom we pack who do exactly this - we warrant our own validated shelf life, and label a duration somewhat longer at the customers' undertaking with their labels, as its the only way they can meet what are often ludicrous minimum shelf life requirements set by their distributors. 

 

Experience of auditors has generally been that they look at one product, have a brief discussion around the rationale behind the "best before" rather than "use by" date (although many don't even bother doing that once they've reviewed HACCP, and that's almost always the first thing audited), ask about ongoing shelf life monitoring, and move on.

 

I've no idea how acceptable it would be for SQF to adopt a combined "validation of (general) process" approach, combined with a high frequency shelf life monitoring plan for the first batch, and further action determined based on the findings of that?

Nonetheless it's what I'd be doing as a BRC certified site.



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#12 springsangel

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Posted 10 October 2019 - 09:16 AM

This has very much been my experience, and generally the auditors with the relevant scope approval to be auditing such facilities will have a reasonable understanding of the same principles. It's a bit reminiscent of the thread a few weeks ago that was discussing the pitfalls/merits of interpretation in the auditing of a standard ;)

 

I can't speak for the US market, but it is certainly not that uncommon in the EU/UK for "best by" ("best before" for the UK) dated ambient-stable beverages, i.e. those for which shelf life and indeed general microbiological stability isn't a limiting factor, to have a shelf life set based to an extent on supply chain operational requirements and realistically exceeding the duration for which the product is actually at its best. A longer life helps meet demanding minimum life on delivery requirements set by retailers and helps at the consumer end as people think they are buying a fresher product if they see it still has e.g. 18 months left.

In practice a lot of these products don't actually last that long, and will taste, smell and/or look rather tired some way before the actual date. For example I'd strongly recommend against drinking any canned beer from certain large brands anywhere near the stated best before date ;)

It's virtually never a problem in practice as the stock is sold through and used long before it reaches end of life, but there is typically an allowance made by the businesses to accept/expect a small number of quality complaints from consumers who have had the misfortune drinking something near the BBE.

 

We have a few brands for whom we pack who do exactly this - we warrant our own validated shelf life, and label a duration somewhat longer at the customers' undertaking with their labels, as its the only way they can meet what are often ludicrous minimum shelf life requirements set by their distributors. 

 

Experience of auditors has generally been that they look at one product, have a brief discussion around the rationale behind the "best before" rather than "use by" date (although many don't even bother doing that once they've reviewed HACCP, and that's almost always the first thing audited), ask about ongoing shelf life monitoring, and move on.

 

I've no idea how acceptable it would be for SQF to adopt a combined "validation of (general) process" approach, combined with a high frequency shelf life monitoring plan for the first batch, and further action determined based on the findings of that?

Nonetheless it's what I'd be doing as a BRC certified site.

 

This has very much been my experience, and generally the auditors with the relevant scope approval to be auditing such facilities will have a reasonable understanding of the same principles. It's a bit reminiscent of the thread a few weeks ago that was discussing the pitfalls/merits of interpretation in the auditing of a standard ;)

 

I can't speak for the US market, but it is certainly not that uncommon in the EU/UK for "best by" ("best before" for the UK) dated ambient-stable beverages, i.e. those for which shelf life and indeed general microbiological stability isn't a limiting factor, to have a shelf life set based to an extent on supply chain operational requirements and realistically exceeding the duration for which the product is actually at its best. A longer life helps meet demanding minimum life on delivery requirements set by retailers and helps at the consumer end as people think they are buying a fresher product if they see it still has e.g. 18 months left.

In practice a lot of these products don't actually last that long, and will taste, smell and/or look rather tired some way before the actual date. For example I'd strongly recommend against drinking any canned beer from certain large brands anywhere near the stated best before date ;)

It's virtually never a problem in practice as the stock is sold through and used long before it reaches end of life, but there is typically an allowance made by the businesses to accept/expect a small number of quality complaints from consumers who have had the misfortune drinking something near the BBE.

 

We have a few brands for whom we pack who do exactly this - we warrant our own validated shelf life, and label a duration somewhat longer at the customers' undertaking with their labels, as its the only way they can meet what are often ludicrous minimum shelf life requirements set by their distributors. 

 

Experience of auditors has generally been that they look at one product, have a brief discussion around the rationale behind the "best before" rather than "use by" date (although many don't even bother doing that once they've reviewed HACCP, and that's almost always the first thing audited), ask about ongoing shelf life monitoring, and move on.

 

I've no idea how acceptable it would be for SQF to adopt a combined "validation of (general) process" approach, combined with a high frequency shelf life monitoring plan for the first batch, and further action determined based on the findings of that?

Nonetheless it's what I'd be doing as a BRC certified site.

Thank you everyone for your feedback.  Several of you were basically saying the same thing.  The majority of the team agree with the concept of, it isn't new, its modified.  We fully intend to do shelf life testing on it, but we cannot accomplish that and meet the customers contract date.  All the normal processes will be followed, microbiology, enviromentals etc.  and we are going to apply a shorter Best Buy date than we believe it is for our own piece of mind while the testing is completed. 



#13 Charles.C

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Posted 10 October 2019 - 04:57 PM

Thank you everyone for your feedback.  Several of you were basically saying the same thing.  The majority of the team agree with the concept of, it isn't new, its modified.  We fully intend to do shelf life testing on it, but we cannot accomplish that and meet the customers contract date.  All the normal processes will be followed, microbiology, enviromentals etc.  and we are going to apply a shorter Best Buy date than we believe it is for our own piece of mind while the testing is completed. 

 

Seems to me that you are choosing to ignore the SQF Guidance.

 

It may be worth remembering that the Guidance material is technically not auditable if the auditor has related queries.

 

Good Luck !

 

PS - afaik, date marking on US consumer goods has no legal implications(?) so I anticipate this enables an increased auditorial flexibility as compared to UK.


Kind Regards,

 

Charles.C


#14 fadetoblack

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Posted 10 October 2019 - 05:17 PM

May help:

 

REGULATION (EU) No 1169/2011, 25 October 2011 Food information to consumers.

 

"Article 24 - In the case of foods which, from a microbiological point of view, are highly perishable and are therefore likely after a short period to constitute an immediate danger to human health, the date of minimum durability shall be replaced by the ‘use by’ date."

 

 * 'date of minimum durability of a food’ means the date until which the food retains its specific properties when properly stored. (Best Before Date)



#15 Charles.C

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Posted 10 October 2019 - 05:33 PM

May help:

 

REGULATION (EU) No 1169/2011, 25 October 2011 Food information to consumers.

 

"Article 24 - In the case of foods which, from a microbiological point of view, are highly perishable and are therefore likely after a short period to constitute an immediate danger to human health, the date of minimum durability shall be replaced by the ‘use by’ date."

 

 * 'date of minimum durability of a food’ means the date until which the food retains its specific properties when properly stored. (Best Before Date)

 

USA ?


Kind Regards,

 

Charles.C


#16 pHruit

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Posted 11 October 2019 - 08:46 AM

USA ?

Not strictly my area of expertise, but seems to be a little more ambiguous - the attached is interesting reading.

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