7 replies to this topic

[nicfarmer12]

Hey everyone, hope you all are making it through this week-It's been a wild week here. We have some samples of product that we are wanting to include in customers orders but are having issues with being able to trace them to the customers. I have several people that just want to toss in the samples and let them go but I feel like these need to be able to be traced back to the customer-even though its free samples. Have any of you ran into this before? We, of course, have lot traceability on everything that gets sent out and even the sample packets that are sent out as a whole are lot traced ( a packet that contains all of the 16 flavors). These select few we just do not want to have to throw away because we over produced and would like to give them away to customers. I hope this makes sense-It does in my head. About our product: We make a tobacco and nicotine free alternative snuff. We are only HACCP certified. Thank you for your thoughts on this!!! Nicole

[Charles.C]

Hi Nicole,

 

Perhaps "alternative to snuff" ?.

[johnmcip]

I'm not sure what the problem here is. Whatever your system is, can't you just treat it like a regular sales order?

[nicfarmer12]

I'm not sure what the problem here is. Whatever your system is, can't you just treat it like a regular sales order?

There is some issue with the website and they can’t create an item for the 5 samples for some reason.

[nicfarmer12]

Hi Nicole,

Perhaps "alternative to snuff" ?.

Not really an alternative to snuff. Since it still going into the mouth and is used in the same manner we still consider it “snuff”. The customers refer to it as snuff as well at times.

[TimG]

Ok, for the life of me I can't find any regulation to back up what I'm about to type (I just tried to look, but still on first cup of coffee so maybe I'll find it a bit later). I've been taught in a classroom that samples and in development product bypasses all FDA requirements (HACCP, Traceability, etc.) as long as it's clearly marked "SAMPLE-NOT FOR RETAIL" or "IN DEVELOPMENT-NOT FOR RETAIL" or something similar.

 

Take that with a grain of salt please, I don't want to spread mis-information if that instructor was incorrect.

If I can find an actual exception in the wording of the the CFR I'll link it..

[nicfarmer12]

Ok, for the life of me I can't find any regulation to back up what I'm about to type (I just tried to look, but still on first cup of coffee so maybe I'll find it a bit later). I've been taught in a classroom that samples and in development product bypasses all FDA requirements (HACCP, Traceability, etc.) as long as it's clearly marked "SAMPLE-NOT FOR RETAIL" or "IN DEVELOPMENT-NOT FOR RETAIL" or something similar.

 

Take that with a grain of salt please, I don't want to spread mis-information if that instructor was incorrect.

If I can find an actual exception in the wording of the the CFR I'll link it..

 

Thank you! I think what we have come up with is to create a log of what order numbers these samples are going in so that we can keep up with who is getting what and when. 

[moskito]

Hi,

 

I can give the answer for EU and how we handle this issue.

Regardless of whether food products are sold or given away, regardless of which distribution channel is chosen, the same rules apply.

Sometimes documentation is not easy, if it is not the regular way of distribution e.g. if you hand over some products to visitors of your plant or business center (customer=consumer) or the sales force exchanges some products in the trade.

 

Rgds

moskito