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ncwingnut

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Posted 31 August 2021 - 07:13 PM

Good afternoon, all!

 

Question - we have always required a lot-specific country of origin for each ingredient we purchase.  We are a flavor manufacturer....we use over 6,500 ingredients and ship to over 36 different countries.  We do not directly import anything.  Any imported product is from brokers, and they are responsible for the FSVP requirements.  

 

We have a supplier that is also a customer.  They have changed the way they do documentation, and want to submit their letter of guarantee as their country of origin.  

 

They are wanting us to cite direct code for the requirement of individual COOs.  That I know of, there is not a requirement for food ingredients - foods such as meat, eggs, etc yes, but ingredients no, or am I thinking wrong?

 

In my tiny brain, a letter of guarantee that does not include a guarantee that the product will always be sourced from the USA, as an example, is not the same as a lot specific COO. There are other countries that expect you to get a lot specific COO that are not necessarily in the US (different codes).

 

Any insight as to how I can answer this one?

 

Thanks much!



olenazh

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Posted 31 August 2021 - 07:24 PM

From my experience of seeing hundreds of LOGs, it usually states that a company guarantees that the products it manufactures are safe for human consumption and comply with all regulatory requirements of the country they're going to be sold in. Something like this. Any other additions are up to them of course, but they cannot require from you whatever is not mandatory.



TimG

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Posted 31 August 2021 - 07:26 PM

I've never heard of lot specific country of origin ... certificates? Does a quality person sign off on it for every lot? That is probably overkill, but I have never been in the flavor industry so perhaps it's something in that industry that ups the risk on origin to require that level.

 

What mmorpg you playing lately? I keep going back to the old ones because everything new sucks..but then I start realizing why I quit playing the old ones.



ncwingnut

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Posted 31 August 2021 - 07:27 PM

From my experience of seeing hundreds of LOGs, it usually states that a company guarantees that the products it manufactures are safe for human consumption and comply with all regulatory requirements of the country they're going to be sold in. Something like this. Any other additions are up to them of course, but they cannot require from you whatever is not mandatory.

 

Yes, that is my experience also.  I am trying to figure out if there is something somewhere that cites that a lot specific country of origin must be provided.  I know in the early stages of FSMA that it was going to be part of the requirements, however, I am wondering if that changed, as I cannot find that reference in the code anywhere.



olenazh

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Posted 31 August 2021 - 07:30 PM

If you can't find it - it most likely does not exist as in our internet era one can find everything there. Don't waste your time, there's no such a regulatory requirement.



ncwingnut

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Posted 31 August 2021 - 07:30 PM

I've never heard of lot specific country of origin ... certificates? Does a quality person sign off on it for every lot? That is probably overkill, but I have never been in the flavor industry so perhaps it's something in that industry that ups the risk on origin to require that level.

 

What mmorpg you playing lately? I keep going back to the old ones because everything new sucks..but then I start realizing why I quit playing the old ones.

 

Since I started here in 2010, we have always required lot specific country of origin for each ingredient received.  We reject them if not provided, and we have always had no issues with our suppliers.  But we have one, who out of the blue, decided they would no longer do this.  Now, they were just bought by a larger conglomerate, so that may be why, but I'm beginning to think this is more our own internal requirement than a code requirement.  I have had overseas auditors from our customers (Japan specifically) require that we have lot specific COOs.

 

I still play Everquest 2.  It's an oldie, but a goodie  :gleam: I've been playing it since it launched.



TimG

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Posted 31 August 2021 - 07:45 PM

Yeah, I still load up EQ 1 and 2 on occasion. Heck, I was in the EQ2 beta and played it for a few years.

Here's to hoping Pantheon works out!






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