Which BRCGS standard ?

Hello,

Looking for a second opinions on the below.

I work for a relatively big, global company with different sites across the globe. The business unit I am in is not GFSI certified and we are preparing to launch new products onto UK markets with retailer brands in near future. The plan is to:

• use our raw materials from plant A - BRC certified
• process RM on plant B - BRC certified
• pack for customers at co-packers- outsourcing - GFSI cert

So the role of the business is development, QA, sale etc. We would be the direct supplier to customer, although not really physically handling the product.

What would you suggest, is the appropriate BRC standard in this scenario.

Also what is your experience dealing with retailers, my understanding is their preference will be to deal with certified business, even in this case

Any suggestions will be greatly appreciated.

Sounds like you want the Agents & Brokers standard - you're supplying the product but not manufacturing it.

If it is UK retailers with whom you're dealing, then yes absolutely the preference is for a certified supplier, and in some circumstances you may find it's a mandatory prerequisite to be considered for supply.

Your position is slightly unusual in that your own sites are a big part of the supply chain and are already certified, but if you're effectively selling product from third-party copackers then you may find there is an expectation/requirement to have Agents & Brokers.

Hi Michael,

I agree with pHruit, you are likely a Broker and fall under the Agents and Broker Standard.

If plant B is your own plant then maybe the certification scope could be extended to include that product and the packing managed as an outsourced process providing after packing the product was returned to plant B before being distributed to customer as per 3.5.4 Management of Outsourced Processing BRCGS Global Standard Food Safety Issue 8.

I would talk to your chosen certification body to confirm, either way with 3 certified sites achieving certification to the Agents and Brokers standard should be relatively straightforward.

Kind regards,

Tony

Thanks pHruit and Tony, that's what i've been thinking, and yes I will be clarifying with CB.

Yes it's to be supplied to uk retailers under their brands.

Scope extension on site B is unlikely, for few reasons incl. that the product is not to be returned on site.

Different question, not brc but haccp/legislation hope that's okay 

What is your view on HACCP plan and responsibilities. Even though physically not handling food, do we still need to have a haccp plan for what we do as we develop the product, outsource, sell etc (I know HACCP will be covered in BRC but let's ignore it for now). IMHO the answer is yes as I think we're still classed as FBO, but opinions seem to be divided as some people suggest that the final safety of the finished product falls onto the final processor/copacker and their HACCP. I think it's partially true, but my argument is that, as we develop, outsource the production and sell the final product (unlike an agent buying some product from a manufacturer to resale) we have the legal responsibility to ensure its safety. Whatever comanufacturers do is on our request and will be covered by contracts and supplier approval etc etc..

Or am I overcomplicating, will be interested to get some second opinions on that.

thanks

Thanks pHruit and Tony, that's what i've been thinking, and yes I will be clarifying with CB.

Yes it's to be supplied to uk retailers under their brands.

 

Scope extension on site B is unlikely, for few reasons incl. that the product is not to be returned on site.

 

Different question, not brc but haccp/legislation hope that's okay 

 

What is your view on HACCP plan and responsibilities. Even though physically not handling food, do we still need to have a haccp plan for what we do as we develop the product, outsource, sell etc (I know HACCP will be covered in BRC but let's ignore it for now). IMHO the answer is yes as I think we're still classed as FBO, but opinions seem to be divided as some people suggest that the final safety of the finished product falls onto the final processor/copacker and their HACCP. I think it's partially true, but my argument is that, as we develop, outsource the production and sell the final product (unlike an agent buying some product from a manufacturer to resale) we have the legal responsibility to ensure its safety. Whatever comanufacturers do is on our request and will be covered by contracts and supplier approval etc etc..

 

Or am I overcomplicating, will be interested to get some second opinions on that.

 

thanks

Hi Michael,

Slightly (reverse?) OT but there is a lengthy previous discussion here for a situation where Company A receives all the packaging/labels for their manufactured retail, branded item from the final distributor B.

The question arose as to where the responsibility lay in the event that a textual error in labelling is discovered after distribution. In UK it seems that, contrary to various expectations, there exists a legal potential to include the activities of Company A.

Possibly a demonstration of a QA axiom that the Quality of a final product is Everybody's "Business".