we are a manufacturer and trader of minerals to be used for food supplement, currently FSSC22000 accredited (B2B only).
we are trading some food products and sometimes we have to repack them, mainly in a bag closed with cable tie in a box or drum. During the repacking, we are sieving through 1mm the powder before introducing it into the new bags and sealing them.
I cannot seem to find any clear guidance on this in FSSC docs. I've checked BRC v8 and the only thing that I could find was within the glossary for manufacturer: "a packer that packs product into retail units from bulk-supplied material can also be classed a manufacturer". FDA also states that : "Generally. FDA regards repackaging as the act of taking a finished drug product from the container in which it was distributed by the original manufacturer and placing it into a different container without further manipulation of the drug" . this does match with what we are doing except that it's really guided to pharmacies or pharma applications.
do you know if we can be classed as a manufacturer for our repacking activities?
what is the difference with a processor/re-processor?
thank you for your help.