Jump to content

  • Quick Navigation
Photo
- - - - -

Labels for Retail Use sent in Foodservice Product Package


  • You cannot start a new topic
  • Please log in to reply
7 replies to this topic

#1 Cryscraz1975

Cryscraz1975

    Grade - Active

  • IFSQN Active
  • 3 posts
  • 0 thanks
0
Neutral

  • United States
    United States

Posted 23 March 2020 - 09:23 PM

Hello,

 

Want to take foodservice items and ship to retail customers and include labels for retail pack packing.  Is there any violation of any GFSI standard, in our case BRC?  I dont see where it would be any violation but a risk is there.  Its not considered co-packing, we are not getting the product back.  Any regulations of advice on this?  Are we okay to include labels in food service packs for repacks to retail with well known customers?  Thanks.



#2 pHruit

pHruit

    Grade - FIFSQN

  • IFSQN Fellow
  • 1,057 posts
  • 473 thanks
223
Excellent

  • United Kingdom
    United Kingdom
  • Gender:Male
  • Interests:Composing/listening to classical music, electronics, mountain biking, science, sarcasm

Posted 24 March 2020 - 10:11 AM

Interesting question. Can't comment on the regulatory side, but BRC has some specific requirements on control of labelling and you'll therefore want to look at if/how you can ensure you're meeting the requirements of e.g. clause 6.2.3.: Procedures shall be in place to ensure that all products are packed into the correct packaging and correctly labelled.

The question that I suspect an auditor would ask, is: If you know the product is destined for retail, how do you know that it is actually being labelled correctly?

Equally one might be able to construct a counter-argument based on BRC's own definition of Primary Packaging to an extent - since this is "the packaging that constitutes the unit of sale to the consumer or customer", and the label isn't part of that if it isn't applied, is it outside the scope of the points in section 6.2? Not perfect though, as it's included in the outer pack so one could also argue it the other way...

 

To me it certainly doesn't look clear-cut as a scenario. Is there a reason you're not applying the retail labels yourself, if you know that's where the product is destined?


 



Thanked by 1 Member:

#3 KTD

KTD

    Grade - MIFSQN

  • IFSQN Member
  • 235 posts
  • 87 thanks
9
Neutral

  • United States
    United States

Posted 24 March 2020 - 12:59 PM

USDA FSIS issued guidance on this topic late yesterday. You can search FSIS's website for Constituent Update and pick the one dated 03/23/20. PDF file attached.

I have not seen or heard anything from the FDA side.

 

Keith

Attached Files



Thanked by 1 Member:

#4 SQFconsultant

SQFconsultant

    SQFconsultant

  • IFSQN Fellow
  • 2,449 posts
  • 649 thanks
497
Excellent

  • United States
    United States
  • Gender:Male
  • Interests:Seeker of truth, T/O, microgreens, making moots cheese, light jazz and being in love.

Posted 24 March 2020 - 02:38 PM

The way I read your posting is that you will be shipping your product to be re-packed and you will be sending the labels to the re-packer to apply to the re-packed units.  

 

Sounds like a contract manufacturer to me - doesn't matter whether the product is coming back to you for distribution or they are distributing it.


Warm regards,

 

 

Glenn Oster

 

 

Glenn Oster Consulting, LLC / 800.793.7042 / USA, Centro & South America

SQF System Development, Implementation & Certification Consultants

Food & Food Storage/Logistics // eConsultant // Internal Auditor Training

www.GlennOsterConsulting.com

 

 

Do it in 3 Steps on the 3rd to the 6th for $33.00...
 

Thanked by 1 Member:

#5 Cryscraz1975

Cryscraz1975

    Grade - Active

  • IFSQN Active
  • 3 posts
  • 0 thanks
0
Neutral

  • United States
    United States

Posted 24 March 2020 - 04:53 PM

Interesting question. Can't comment on the regulatory side, but BRC has some specific requirements on control of labelling and you'll therefore want to look at if/how you can ensure you're meeting the requirements of e.g. clause 6.2.3.: Procedures shall be in place to ensure that all products are packed into the correct packaging and correctly labelled.

The question that I suspect an auditor would ask, is: If you know the product is destined for retail, how do you know that it is actually being labelled correctly?

Equally one might be able to construct a counter-argument based on BRC's own definition of Primary Packaging to an extent - since this is "the packaging that constitutes the unit of sale to the consumer or customer", and the label isn't part of that if it isn't applied, is it outside the scope of the points in section 6.2? Not perfect though, as it's included in the outer pack so one could also argue it the other way...

 

To me it certainly doesn't look clear-cut as a scenario. Is there a reason you're not applying the retail labels yourself, if you know that's where the product is destined?

 

The products are value added seafood items already packed as food-service.  Due to demand, retail customers want the products and are requesting to buy, repack and label themselves.  The customers will buy product and sell themselves, no redistribute to another customer.

 



#6 FoodSafetyPlanet

FoodSafetyPlanet

    Grade - MIFSQN

  • IFSQN Member
  • 82 posts
  • 28 thanks
15
Good

  • United States
    United States
  • Gender:Female

Posted 25 March 2020 - 04:26 AM

The products are value added seafood items already packed as food-service.  Due to demand, retail customers want the products and are requesting to buy, repack and label themselves.  The customers will buy product and sell themselves, no redistribute to another customer.

 
Game over at seafood. Not worth the risk. 


Thanked by 2 Members:

#7 Cryscraz1975

Cryscraz1975

    Grade - Active

  • IFSQN Active
  • 3 posts
  • 0 thanks
0
Neutral

  • United States
    United States

Posted 25 March 2020 - 03:04 PM

 

The products are value added seafood items already packed as food-service.  Due to demand, retail customers want the products and are requesting to buy, repack and label themselves.  The customers will buy product and sell themselves, no redistribute to another customer.

 
Game over at seafood. Not worth the risk. 
 
That was my thought as well.  Thanks.

 



#8 SQFconsultant

SQFconsultant

    SQFconsultant

  • IFSQN Fellow
  • 2,449 posts
  • 649 thanks
497
Excellent

  • United States
    United States
  • Gender:Male
  • Interests:Seeker of truth, T/O, microgreens, making moots cheese, light jazz and being in love.

Posted 25 March 2020 - 03:08 PM

I agreee with FoodSafetyPlanet - bucoo risk for your company.


Warm regards,

 

 

Glenn Oster

 

 

Glenn Oster Consulting, LLC / 800.793.7042 / USA, Centro & South America

SQF System Development, Implementation & Certification Consultants

Food & Food Storage/Logistics // eConsultant // Internal Auditor Training

www.GlennOsterConsulting.com

 

 

Do it in 3 Steps on the 3rd to the 6th for $33.00...
 




0 user(s) are reading this topic

0 members, 0 guests, 0 anonymous users

EV SSL Certificate