SQF requirement for labeling of foods with customer provided labels
Anyone else in co-manufacturing where the customer provides the labels or printed packaging materials? What is your practice/procedure for complying with the SQF requirement below? Other than confirming there is the correct allergen declaration, what do you inspect for? What records do you keep? 2.3.2.7 Finished product labels shall be accurate, comply with the relevant legislation, and be approved by qualified company personnel. 2.8.1.9 The site shall document and implement methods to control the accuracy of finished product labels (or consumer information where applicable) and assure work-in-progress and finished product are true to label with regard to allergens. Measures may include label approvals at receipt, label reconciliations during production, destruction of obsolete labels, verification of labels on finished product as appropriate, and product change over procedures.
Greetings,
Not an SQF expert, but through my experience in other schemes, you have to be more vigilant with checks of the labels/packages they send you. It's not only allergens, since -for whatever reason- they may suddenly add eg a health claim that is not true or alter some other information like the nutrition facts or the ingredient list in general (adding or extracting something). Or the labels may be misprinted and the information are not readable.
Your appropriate personnel should do regular checks (maybe even sampling every lot you receive??) of the provided labels for inconsistencies. To simplify that check you can have a set label that is already approved and have the labels that come after that compared to the original before being used (having always in mind though possible legislation changes/amendments or marketing-oriented changes in which case you only update the set label if the crucial info are not affected).
The record you should keep is the approval of the label/package with the appropriate tracing clues (lot, date, sign etc)
Hope it helps!
Who owns the product???
If the customer owns the product 100%, you are only responsible for ensuring the correct label is used on the correct product. A simple reconciliation of labels in, used, wasted and out should do the trick
If you BOTH own the product, than you'll need a label review done annually and upon delivery receipt as well as the above list
JFI and as an extension of Post 2, a similar query generated a lengthy thread on BRC's Forum.
It seems intuitively unreasonable but IIRC, it was documentarily established that, at least in UK, the user of the supplied Label shared in the legal fall-out of a mislabelling in the event of any subsequent related safety incident. US may be different of course.
One thing I have always done in the past, and you do not state that this is a issue, but I feel is worth mentioning is that if the labels are sent to you in a foreign language to be applied to product I send them off to a 3rd party to be verified. This ensures that there is no bias in the wording and that that the label is true to what was agreed upon. As for records I would have the customer sign a stated use page with the label attached and file it with production documents.