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Posted 23 November 2021 - 05:58 PM

Hello all,


We are Organic raw materials supplier and processor. One of our customers are BRC certified and recently they have asked us for the last manufacturer's information. 


To us that is classified information (for obvious reasons) and also, we repack most of the items, making us the 'last manufacturer' on record.


Not to mention that once the materials are in our possession, whatever happen to them become our responsibility.


Am I wrong in my assumption? 




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Posted 23 November 2021 - 06:18 PM

Hi cosmicbrat; I don't think the fact that you repack the product makes you a manufacturer. I have the same situation (but on the other side of barricades:)): I always request MANUFACTURER information regardless whom the product was repacked or distributed or whatever.


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Posted 23 November 2021 - 06:22 PM

Hi Cosmic, this exact question has come up a few times. I chimed in on the most recent thread, which you can find here:



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Posted 24 November 2021 - 11:28 AM

Any of your customers who work to the BRCGS Food standard will require the identity of the last manufacturer or packer, with clause stating:



"The site shall have an up-to-date list or database of approved suppliers. This may be on paper (hard copy) or it may be controlled on an electronic system.
The list or relevant components of the database shall be readily available to the relevant staff (e.g. at goods receipt).
Where raw materials (including primary packaging) are purchased from companies that are not the manufacturer, packer or consolidator (e.g. purchased from an agent, broker or wholesaler), the site shall know the identity of the last manufacturer or packer, or for bulk commodity products the consolidation place of the raw material.
Information to enable the approval of the manufacturer, packer or consolidator, as in clauses and, shall be obtained from the agent/broker or directly from the supplier, unless the agent/broker is themselves certificated to a BRC Standard (e.g. BRC Global Standard for Agents and Brokers) or a standard benchmarked by GFSI."


Since you re-pack the material, it should be sufficient for your customers to record your site as the packer. In reality, a refusal to disclose information about the supply route for input materials may result in your customer declining to approve supply because many food manufacturers who engage in BRCGS compliance also trade with retail customers (directly or indirectly), and there's an expectation of supply chain transparency.

Just anecdotally, I am not currently engaged in food manufacturing and I now provide software services... But in case it helps you to understand, when I was administrating supplier approval records for food manufacturers I would have strongly encouraged the purchaser to look for alternative sources for any raw materials if there was any resistance to my requests for technical information. I'd always be thinking 'why approve this supply route with the information deficit, when I can just put my foot down and have procurement find a more agreeable source?'


So.. I definitely think it's a valid argument to say your customers may not require that information for compliance alone - but refusal to provide it may still cost you those customers.

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Posted 24 November 2021 - 12:03 PM

If you yourself are BRC certified then I think all the BRC Standards now say that you must provide the information. However during your audit, the auditor will have very little chance of finding that out unless he had previous knowledge. This could happen if your customer complains to the BRC knowing that you are certified.


He could get a NC in his audit for your non disclosure which will annoy him.


If you are not certified, there is nothing to force you to disclose other than commercial pressure (except to enforcement agencies). There are some customers who will happily leapfrog a supplier to get a better deal direct, including big companies and retailers (It has happened to my knowledge as recently as August) If you are a small business you will be hit comparatively harder.


If you don't tell them you may lose the customer. If you do tell them you may also lose the customer by them going direct.


Non Disclosure Agreements may be enough to discourage them but they have to be carefully written and they are difficult to enforce.


Not all companies are honourable and it is unfortunately a commercial calculation.


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Posted 24 November 2021 - 02:02 PM

So from what I see from what Duncan posted for the BRC standard:

..site shall know the identity of the last manufacturer or packer 


But I also notice that you said:

..we repack most of the items

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