Supply chain requirements...finding it difficult to get COA's
As we all know one of the biggest PAINS in food business is the food supply chain. I am trying to find and know the correct procedure in place to stay in compliance with federal regulations. Any help would be appreciated.
So we purchase candies from a supplier. These candies are either in bulk not individually packaged (gummy worms) and some come in bulk but individually packaged (packaged lolipops. both of these types go in bags, which is done by us. (so some go in primary packaging and some in secondary.
This supplier buys it from an IMPORTER. This importer is in the USA and they buy from their company in Mexico. So it really is the same company in Mexico in USA but they have their office here where they import it from their manufacturing site in Mexico.
SO:
Manufacturer (Mexico) - Importer (USA)- Buyer from Importer (USA) - Then us.
So we dont get any COAs of these candies. The buyer from the importer say they dont require their importer any documentation (weird since importer must follow FSVP). So in turn I am not receiving any COAs of these candies! And I need to! It's frustrating since importer should request them from the manufacturer and they must be forwarded down the supply chain leading to us, CORRECT?
Any help on what I can do?? Has anyone been in this situation? Any regulation maybe I am missing on these candies?
Hi Food Sci, we are in a similar scope (confections that we do not manufacture, but purchase and then package ourselves). I had the same issue with you with COAs being neglected. We purchase from Mexico as well.
Can you directly contact the manufacturer to get one? That is what I did when an importer could not supply one. You are correct in your supply chain statement - for us it was particularly urgent since we were about to audit which is why I contacted the manufacturer as a last resort.
We also send product (before purchasing / pre-production samples) and test ourselves, which our auditor mentioned could bypass COA if we wanted to.
Perhaps your purchasing or buyer should address this in to the importer when purchasing (making a note in the PO) - or creating a training with relevant staff on what should be expected of documentation when buying in the first place? I know this was the game changer for our company in keeping up compliance - to only purchase from suppliers that can comply with your documentation standards.
This is from the FDA's Foreign Supplier Verification Programs for Importers of Food for Humans and Animals:Guidance for Industry: