4 replies to this topic

[BYFood]

Hi

 

We are a food flavouring manufacturing company, under management of purchased materials 2.5.1(d), the organization shall establish, implement and maintain a review process for product specifications to ensure continued compliance with food safety, legal and customer requirements. 

 

Our ingredients involve liquid or powder flavours from other company too, but due to proprietary information that cannot be disclosed, is there any way that we can review for this kind of ingredients?

[Evans X.]

Greetings,

 

I have to argue the fact that they cannot be disclosed. The only "secret" if it is a pattent or something relevant would be the mentioning of the exact ingredients. However that doesn't mean that they can't provide you with specifications in which they describe what microbiological/ chemical/ allergen they check for, storage conditions, labelling information, shelf-life, its intended use, and even more what additives they use if any (because some have limits from legislation and you need to know so you don't pass that limit if you intergate these in your end products etc.).

Or at the very least provide you with a signed Letter of Conformity mentioning that the products they provide you are safe for use and according to the current safety/ legal/ cust. requirements. This can also be backed up with analysis reports from accredited laboratories with a focus at least on the possible pathogens.

 

Bottom line is they have to provide you something you can use as evidence that the product is safe. What's more non-disclosure covers only up to the point that they don't tell you how they make it and what quantities of each ingredient they put in their product. An example I use often is that Coca Cola does have the ingredients of their product on the label, but the quantities of each are of course not given (hence there goes the proprietary information you mentioned). Furthermore, almost in all countries worldwide any food or drug is required by law to mention the ingredients it is made up from.

 

My personal opinion is start searching for another supplier if they don' comply.

 

Regards!

[olenazh]

Completely agree with Evans X: it's a supplier responsibility to provide all necessary information about the products they supply, including specification.

[Charles.C]

Hi

 

We are a food flavouring manufacturing company, under management of purchased materials 2.5.1(d), the organization shall establish, implement and maintain a review process for product specifications to ensure continued compliance with food safety, legal and customer requirements. 

 

Our ingredients involve liquid or powder flavours from other company too, but due to proprietary information that cannot be disclosed, is there any way that we can review for this kind of ingredients?

Hi Byfood,

 

You may consider what your defence will be in the event of a claim potentially due to such ingredient(s) within your own product.

[pHruit]

Hi

 

We are a food flavouring manufacturing company, under management of purchased materials 2.5.1(d), the organization shall establish, implement and maintain a review process for product specifications to ensure continued compliance with food safety, legal and customer requirements. 

 

Our ingredients involve liquid or powder flavours from other company too, but due to proprietary information that cannot be disclosed, is there any way that we can review for this kind of ingredients?

I don't know your local regulations in this area, so can only answer from an EU perspective, but hopefully there will be sufficient similarity to take something useful from this.

 

I've worked for flavour companies. The actual formulations are legitimately considered as Intellectual Property - this is what makes the flavouring taste/smell the way it does, and developing these formulations costs a lot of money in R&D etc.
However, with most flavouring regulations you don't need the full formulation to adequately characterise the flavouring from a legal perspective, nor to provide sufficient information from a food safety perspective.

 

What content is your supplier currently providing in the specifications they issue?

I'd expect them to be no different to those they issue to other customers, as I'd be surprised if any of their clients get access to full formulation details - there might be certain exceptions for extremely large customers, subject to various non-disclosure agreements etc, but IMEX this is very much exceptional rather than normal.

In terms of characterising the product for compositional/legal purposes I'd expect to see would be legal name (e.g. "natural flavouring", "natural <name of food> flavouring" etc), basic compositional information confirming what type of flavour components are present - i.e. are these flavouring substances, natural flavouring substances, flavouring preparations etc - and probably a % breakdown for any carriers used (e.g. ethanol, propylene glycol). If any of the flavour components are restricted (e.g. subject to maximum limits in food products) then these should also be identified along with an indication of the level present, as the user has to know this information to be able to ensure that they're using the product in compliance with applicable regulations.

Additionally I'd expect to see allergen status, shelf life, storage conditions etc the same as for any other food ingredient.