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CoA for re-processing manufacturing

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Sarahb3339

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Posted 09 July 2021 - 03:13 PM

Hello, our company is SQF certified and I recently have a request from a new possible customer.  We reprocess/repack bulk material that we receive from another company that actually manufactures it. When we receive it, we apply our HACCP processes to the material and screen, repack, and test the material before shipping. The CoA's come from our company and have us listed as the manufacturer as we mix lots of the material and test and retest ourselves as we are processing it.  We have  a request from a possible customer to have the actual manufacturer of the ingredient listed on our CoA vs us as their argument is we are not the manufacturer.  This is tricky to me because we are actually testing this material. They are asking us to add the name of our supplier to our coa even though our supplier is not reprocessing, assigning new lot codes, or testing the material, we are doing this. The CoA would be linked to OUR lot codes and processes and testing , therefore omitting our name makes no sense to me... Any thoughts or feedback on this situation.?



YNA QA

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Posted 09 July 2021 - 03:55 PM

I've personally never had this type of request, but we do some of the same type of processing.  Honestly we would tell them no.  That is your vendor, and once it leaves them and you re-pack/ or re-process it, this is now your material, and you are responsible for any FS/Q issues.

 

Does this customer know the manufacturer that you get it from? Could they just be trying to go around the "middle-man" and try to do this process themselves?

 

We tell all customers that our vendors are proprietary, and we do not disclose.  

 

Now if this is potentially major business, that could bring in large amounts of revenue, then you could re-consider and on the COA do a :initial manufacturer and then final processor and place both on the COA.  Seems tedious but it may satisfy your customer and be a small change to make.



pHruit

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Posted 09 July 2021 - 05:11 PM

I used to get the opposite - traders in the business wanting us to send the original manufacturer's CoA to hide that we'd done any sort of repacking / further processing, usually because they'd made an ill-considered contract to supply product from factory X in a size/format that factory X didn't offer...

 

For these type of repacking processes, it is now relatively common here in the UK for the customer to want to know who the "actual" manufacturer is, but this doesn't extend to the type of data presentation that is being requested from you.

 

If you do decide to consider going down the route of using your supplier's name, you may want to discuss it with them first. Would you want your business name on someone else's analysis, for a product that has been through someone else's process / HACCP plan after it left your control? I know I wouldn't, unless I had fully approved them as a subcontractor and treated them as one, such that I had full confidence in what they were doing.



SUSHIL

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Posted 10 July 2021 - 08:02 AM

You can demonstrate to them that you have Traceability System in Place and in case of any issues Food Safety or any other issue you can easily Trace the issue to the Original Manufacturer of the Ingredients.
For this Customer you can keep record seperately of Ingredients used and their Manufacturer,along with Lot No's etc at your end and Show them when demanded.





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