11 replies to this topic

[Sphadnis]

Hello all,

 

I am fairly new to quality control, and am posting here for some information. I am working for a brewery that has previously manufactured beer, but more recently started making coffee and tea as well. We are planning to start toll manufacturing 

 

Where could I find some information on the various laws and regulations we will need to follow, and all of the certifications we will need? We currently finished Halal and are working on organic. I know that SQF is important as well, but I am not sure if it is legally required 

 

Thank you!

[pHruit]

Hi, welcome to the forum

Whereabouts is your factory? Regulations and requirements differ between countries

Certifications like SQF and the competing GFSI-benchmarked standards aren't usually a mandatory legal requirement, but they can help you operate better (if implemented well...) and are often useful for attracting and retaining customers.

[Sphadnis]

Hi, welcome to the forum

Whereabouts is your factory? Regulations and requirements differ between countries

Certifications like SQF and the competing GFSI-benchmarked standards aren't usually a mandatory legal requirement, but they can help you operate better (if implemented well...) and are often useful for attracting and retaining customers.

Hello! Thanks for the welcome

 

We are located in the United States currently and do not plan to export any product to other countries 

[pHruit]

Ok, the US isn't my area of expertise, but I'd expect you'll fall under FSMA - the FDA has a large amount of info linked from their main page on it here: https://www.fda.gov/...zation-act-fsma

Generally as a contract packer you'll probably be subject to most of the regulations applicable to any other food business, although things like labelling will depend to an extent on what you're responsible for vs. what your customers are responsible for in terms of design/content.

There are loads of knowledgeable people here from the US who'll probably chip in with some more specific advice on general US regulatory requirements.

 

Even if you don't want to pursue SQF or similar immediately, it's probably worth downloading a copy of the standard as a useful reference on broad structure and things to consider for setting up your food safety systems. I think SQF is available for free on their website, and the BRC standard is definitely available free from the BRCGS Bookshop: https://www.brcgs.co...-issue-8/p-616/

[kfromNE]

You'll fall under FDA regulation. Are you shipping/selling this product across state lines or selling on the internet. 

 

Shipping across state lines and/or selling on the internet - you are now under federal regulations. If this these are food service items (high doubt it) then a nutrition facts label isn't required. If selling individually - nutrition facts panel is required as well. 

 

Your state FDA website should have valuable information you would need even about federal regulations. Also your local land grant university may be able to help as well especially if you are a small business. 

[kfromNE]

Other potential helpful websites

 

https://www.canr.msu..._Validation.pdf

(About meat items but many of the items are relevant to FDA as well)

 

https://www.ag.ndsu....oodlaw/overview - the best easiest and reputable website I've found to understand all of the FDA regulations

[Sphadnis]

You'll fall under FDA regulation. Are you shipping/selling this product across state lines or selling on the internet. 

 

Shipping across state lines and/or selling on the internet - you are now under federal regulations. If this these are food service items (high doubt it) then a nutrition facts label isn't required. If selling individually - nutrition facts panel is required as well. 

 

Your state FDA website should have valuable information you would need even about federal regulations. Also your local land grant university may be able to help as well especially if you are a small business. 

Hi, thanks for your response

 

We are currently not planning to ship out of state or sell through the internet. For the labeling requirements, since we are not selling food service items, does this mean that a nutrition facts label is required? And when you say "if selling individually" since we are selling coffee, do this mean individual coffee cans?

[kfromNE]

Hi, thanks for your response

 

We are currently not planning to ship out of state or sell through the internet. For the labeling requirements, since we are not selling food service items, does this mean that a nutrition facts label is required? And when you say "if selling individually" since we are selling coffee, do this mean individual coffee cans?

You will fall under state regulations. With that - you may not need a nutrition facts label. Double check your state food code. Individual coffee cans are considered 'individual'.

[Sphadnis]

You will fall under state regulations. With that - you may not need a nutrition facts label. Double check your state food code. Individual coffee cans are considered 'individual'.

 

Thank you kfromNE! I do apologize for all of the questions, but something else I was wondering was what are the difference between federal and FDA regulations? I had assumed that FDA was a category of federal regulation. Unless in this case, FDA regulations are referring to state regulations and not nationwide regulations 

[kfromNE]

Thank you kfromNE! I do apologize for all of the questions, but something else I was wondering was what are the difference between federal and FDA regulations? I had assumed that FDA was a category of federal regulation. Unless in this case, FDA regulations are referring to state regulations and not nationwide regulations 

A lot. State - says how you have to do it. Federal - gives guidelines then says prove how your policies and procedures follow those guidelines.

 

The state guidelines are a lot easier than federal. I'd call your local county health department. Tell them what you are doing and have them tell you what guidelines you need to follow.

 

FDA is both. They create the federal food code - which then states adapt. https://www.fda.gov/...n/fda-food-code

 

Then there's the federal code - known as FSMA.

 

https://www.fdareade...da-jurisdiction

Edited by kfromNE, 14 February 2022 - 07:17 PM.

[Brendan Triplett]

Hey Sphadnis,

 

Do you have a current HACCP in place?  I imagine that there are food safety protocol in place already since you worked with Halal.  I did work with them as well and they needed something close to HACCP to be happy.  It is a good place to start if you want to have something solid in place before pursuing a third party audit certification.

 

What products/materials will you be handling with your toll manufacturing?  This could have an impact on your program as well.

 

Cheers!

[Sphadnis]

Hey Sphadnis,

 

Do you have a current HACCP in place?  I imagine that there are food safety protocol in place already since you worked with Halal.  I did work with them as well and they needed something close to HACCP to be happy.  It is a good place to start if you want to have something solid in place before pursuing a third party audit certification.

 

What products/materials will you be handling with your toll manufacturing?  This could have an impact on your program as well.

 

Cheers!

Hey Brendan,

 

I am HACCP certified and have created a production flowchart with hazard analysis, and we do have employees trained in GMPs such as allergen control, pest awareness, etc 

 

As far as the products we will be handling, I don't have a comprehensive list of packaging materials at the moment (though I know I should create one as soon as I can), but we are mainly working with roasted coffee beans and tea leaves as raw materials.