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What regulatory documents are needed for a broker?


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hannahharo

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Posted 06 October 2020 - 03:54 PM

Hello,

 

I am updating our supplier documents and I need help with how to handle brokers. We buy several juice concentrates through a broker/trader. We already ask for regulatory documents for all the juices they provide but I'm uncertain on what i need to ask of them. What kind of regulatory documents do we need to satisfy the supplier approval requirement for SQF?

 

Thanks!



SQFconsultant

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Posted 06 October 2020 - 04:07 PM

You would go by your current approved supplier program and akso require FSVP (FDA) for any food imported by the broker (assuming you are in the us).


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Ryan M.

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Posted 06 October 2020 - 08:58 PM

Exactly what Glenn said.  Brokers should be able to supply you the same information as your supplier.  I've attached a couple documents that should be helpful, but please bear in mind these are 2015 dated.  FSVP was not in place at this time so it is not on the documents; you can definitely add it or revise as needed to your suiting.


Edited by Ryan M., 06 October 2020 - 08:59 PM.


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hannahharo

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Posted 07 October 2020 - 01:03 PM

You would go by your current approved supplier program and akso require FSVP (FDA) for any food imported by the broker (assuming you are in the us).

 

 

Exactly what Glenn said.  Brokers should be able to supply you the same information as your supplier.  I've attached a couple documents that should be helpful, but please bear in mind these are 2015 dated.  FSVP was not in place at this time so it is not on the documents; you can definitely add it or revise as needed to your suiting.

 

Our juice broker tells me he is only able to provide proof of insurance for his broker company and he can provide supplier documents from the juice manufacturers. The broker does not import any of the juices we purchase they are just the "middle man" between us (customer) and manufacturer. I'm thinking they should be able to provide some sort of letter of guarantee or something other than just a COI. Any thoughts?



Ryan M.

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Posted 07 October 2020 - 02:22 PM

The broker is correct.  You should get most of your documentation from the actual juice supplier.  The broker is the one to be the middle man in your communication concerning this.  However, the broker does have responsibility with FSVP and insurance as they noted.

 

The letter of guarantee and food safety documentation should come from the juice supplier, not the broker.  The broker needs to verify the supplier has met the FSVP requirements.  See the link below from FDA regarding FSVP requirements and how to meet the requirements.  FYI, the broker is considered the importer, not you.

 

https://www.fda.gov/...know-about-fsvp

 

 

Our juice broker tells me he is only able to provide proof of insurance for his broker company and he can provide supplier documents from the juice manufacturers. The broker does not import any of the juices we purchase they are just the "middle man" between us (customer) and manufacturer. I'm thinking they should be able to provide some sort of letter of guarantee or something other than just a COI. Any thoughts?



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hannahharo

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Posted 07 October 2020 - 02:27 PM

The broker is correct.  You should get most of your documentation from the actual juice supplier.  The broker is the one to be the middle man in your communication concerning this.  However, the broker does have responsibility with FSVP and insurance as they noted.

 

The letter of guarantee and food safety documentation should come from the juice supplier, not the broker.  The broker needs to verify the supplier has met the FSVP requirements.  See the link below from FDA regarding FSVP requirements and how to meet the requirements.  FYI, the broker is considered the importer, not you.

 

https://www.fda.gov/...know-about-fsvp

 

Thank you! This clears it up for me.



moskito

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Posted 08 October 2020 - 03:13 PM

We avoid to buy raw materials via broker/trader, where possible. If this is necessary we require that all docs filled and signed by the manufacturing plant (as we have for all supply from manufacturers delivering directly). Of course this is dependent from your procurement power (means budget and company size), the QA agreement and NDAs. It is not easy and in some cases not possible, but we stick to these principles.

 

Rgds

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Ken Bookmyer

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Posted 12 October 2020 - 02:28 PM

in my limited experience the auditor wants 1) a product specification and  2) either a COA or a continuing letter of guarantee. Your broker should be able to supply a continuing letter of guarantee if not I'd suggest getting another broker. The COA would need to come from the supplier. Oddly enough SQF does not accept SQF certification of your supplier as adequate. Makes you wonder about the true value of SQF if they don't even accept it for themselves. 

ken






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