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#1 DEG

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Posted 22 October 2019 - 02:52 PM

Good day, first post here.

 

As background, I work for a USA based company and one of our divisions is focused on the domestic marketing, sales, and distribution of animal feed supplements (AKA food for animals).  We are not basic in manufacturing.  We'll either take in a product from a manufacturer and re-sell it in original packaging, or we'll it send to a toll processing partner to perform any further manufacturing and re-packaging necessary.  Since we're not a manufacturer, our company has not invested in what I'll call Food Safety & Regulatory staff.  We lack staff with expert level knowledge of FSMA, have no PQCI, etc.  To me this is a huge mistake.  But that's not the point of this post...rather it gives context to my following noob level question.

 

Last month we delivered some product enclosed in bagged packaging to a customer.  Yesterday, customer contacted us with a desire to return the goods.  Typically, our sales policy is "all sales are final".  Over the years we have made rare exceptions to this largely based on future customer relations consideration.  In discussing internally whether or not we would grant customer request to return, some of my colleagues have mentioned that FSMA would bar us from taking product back.  I do not think this is correct--I do not believe that FSMA dictates a one way supply chain where no goods can ever flow in reverse.  Now FSMA may place a burden upon us to be more critical in evaluating the risk of these returned goods, based on circumstance, and their future purpose.  But this should be different from barring product returns.

 

Wondering if anybody can confirm if my thinking is at least "in the ballpark" of being correct?

 

Thanks, I look forward to learning from your knowledge.  This site and forum seem a great resource.



#2 SQFconsultant

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Posted 22 October 2019 - 03:19 PM

FSMA does not dictate whether you can or can not take returns.

 

Your company needs to get at least an FSMS in place and fast.


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#3 FSQA

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Posted 22 October 2019 - 08:11 PM

Good day, first post here.

 

As background, I work for a USA based company and one of our divisions is focused on the domestic marketing, sales, and distribution of animal feed supplements (AKA food for animals).  We are not basic in manufacturing.  We'll either take in a product from a manufacturer and re-sell it in original packaging, or we'll it send to a toll processing partner to perform any further manufacturing and re-packaging necessary.  Since we're not a manufacturer, our company has not invested in what I'll call Food Safety & Regulatory staff.  We lack staff with expert level knowledge of FSMA, have no PQCI, etc.  To me this is a huge mistake.  But that's not the point of this post...rather it gives context to my following noob level question.

 

Last month we delivered some product enclosed in bagged packaging to a customer.  Yesterday, customer contacted us with a desire to return the goods.  Typically, our sales policy is "all sales are final".  Over the years we have made rare exceptions to this largely based on future customer relations consideration.  In discussing internally whether or not we would grant customer request to return, some of my colleagues have mentioned that FSMA would bar us from taking product back.  I do not think this is correct--I do not believe that FSMA dictates a one way supply chain where no goods can ever flow in reverse.  Now FSMA may place a burden upon us to be more critical in evaluating the risk of these returned goods, based on circumstance, and their future purpose.  But this should be different from barring product returns.

 

Wondering if anybody can confirm if my thinking is at least "in the ballpark" of being correct?

 

Thanks, I look forward to learning from your knowledge.  This site and forum seem a great resource.

 

FSMA, do not dictate you about the product return policy, but it does makes you responsible for Product safety in the supply chain (as you mention about risks associated with the returned product).

 

Risks can vary based on the type of product (persihable/shelf stable/Food fraud,etc). 



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