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#1 larissaj

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Posted 14 October 2020 - 01:04 PM

Hello,

 

I hope this isnt too dumb of a question. My company has a wholesale business and a retail business. Two different things here but with the same name. Recently the retail store moved to online sales and has moved into our manufacturing plant. They have a couple different products that they offer online but not too much, everything else are products we manufacture. Allergens are the same and they use are programs and what not for GMPs HACCP ETC. 

 

My question is, do they have to have their own FDA registration number? Or can they fall under ours? They are under our roof and they do everything we do it's just the way they sell is straight to the customer where as we sell to different companys (wholesale)



#2 SQFconsultant

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Posted 14 October 2020 - 01:23 PM

Client did same thing - it is the same FDA registration.


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#3 kfromNE

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Posted 14 October 2020 - 03:18 PM

Going to on-line sales - make sure you are compliant with all laws in other states (California). I know of companies sued because they didn't follow one of the California label laws (declaring a certain item on the label, I forget which one). There are people out there who make a living suing companies.



#4 Ryan M.

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Posted 14 October 2020 - 07:29 PM

This.  Prop 65 has been a nuisance in California.  But there are other caveats for California in terms of labeling that are different from other states.

 

Going to on-line sales - make sure you are compliant with all laws in other states (California). I know of companies sued because they didn't follow one of the California label laws (declaring a certain item on the label, I forget which one). There are people out there who make a living suing companies.



#5 kfromNE

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Posted 14 October 2020 - 07:55 PM

Another thing to watch out for - a company I worked for sold their items on-line. The people putting the items and content on the website didn't know the FDA/USDA had rules and didn't consult with anyone. There were health claims stated on the website that couldn't be backed up. Luckily I did look at the website and informed them before they could get in trouble with this. Health claims being the ones you would see on labels.



#6 Ted S

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Posted 15 October 2020 - 06:51 PM

In addition, if these products are sold to consumers that live outside of the US, must make it clear that the product is only labelled for US Allergens. Canada, for example, requires additional Allergens be labelled that the US does not require. 






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