Retail labeling
Hi everyone, I was wondering if someone could help point me in the right direction. We currently sell our products to restaurants, gas stations etc, through distributors. We are wanting to start selling our product to retail stores. I am being told that since our product contains tea, that we need to have a statement on the packaging to cover us on the microbial side of things. I am not finding anything that helps me with this. Normally you would brew our product with boiling water so it takes that out of the equation, but if someone was to use cold water? What does the statement need to say to cover that.
Can you give an example of the kind of disclaimer you're talking about? And what sort of authority is giving you this instruction? I have never seen tea sold with a warning listed that it should only be consumed at your own risk due to "microbial issues". Sure many teas have serving instructions that recommend water temperature and steeping time, but this isn't done for the same purpose as cooking instructions on meat packaging. I'm not involved in the tea industry but it's just not something I've seen before. I did find some recommendations from THIE (Tea and Herbal Infusions Europe) on microbial load for tea products. But I am not very familiar with this organization.
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Hi, I had a conversation with a consultant, and he told me that on the label we need to add "the boiling water" statement as a kill step. If we didn't we would have to get validation from our tea source on every lot code and then turn around and send that information to everyone that we would sell to on each load. I have looked at others packaging like a Lipton or Luzianne and I am not seeing anything on those packages.
It sounds like his advise is based on the fact that you don't currently have a supplier approval program. Is this true? For every inbound lot of tea, does your company test the material against some microbial specification? Do you source your tea from suppliers that you have vetted through some kind of supplier auditing program, or do you instead stick with suppliers that are certified through some tea grower's GAP body? Basically, you need to have measures in place to determine if the tea you sell to customers is safe to consume in the manner you would like them to (hot or cold brew). If you aren't familiar with the microbial risks in your raw material, and you in turn aren't testing your raw material to vet lots based on this risk, it will be difficult for you to say it's ok for cold-brew. This may be what your consultant is referring to.
Yes, we do have a supplier approval program. We currently do not test each load that comes in since we receive a COA with the loads with their testing. I send samples off once a month to a 3rd party for testing. Would their testing be sufficient enough, or would I need to also send off samples?
It would be hard to be too prescriptive without knowing a lot about your process or the materials involved. It sounds like your consultant is opting for increasing your testing to a lot-by-lot sort of scheme rather than monthly testing. Depending on your volume, monthly testing may not be frequent enough to be representative of all finished goods you release. Sure you get COAs on every lot, but what about risks introduced by your own handling of the raw material? (Blending equipment, packaging, staging, etc.) Even in low-risk foods, you should have some reasoning to support your decision for infrequent testing. Having a history of lot-by-lot testing showing that you make clean product is a good place to start. Once that is established you may be able to justifiably reduce testing frequency.
A justification for whether your testing is "enough" is typically based on a risk assessment of your particular product recipe, facility (environmental monitoring), processing method, intended use, and statistics. If you intend/expect customers to brew your tea cold, is that accounted for in your microbial specifications? What risks are present in this brewing method as opposed to boiling water, and how do you mitigate those risks? If your position is that your finished product is safe to consume as cold brew, you should have a suite of data/information to support that stance. Your consultant might be saying that your current justification is lacking and should be supported by more data. I'm not sure, however, what he means by getting "validation from every tea source" if you're already getting COAs.
Maybe some more conversations with your consultant are in order? Lipton has the resources to do whatever validation projects they'd like to to justify their product's safety. But there are plenty of smaller tea blenders that don't bear this sort of warning on their product either. So there must be some kind of reasonable direction your company could take to be compliant. Unfortunately I don't have experience with the industry so I don't know the norm.
Can I ask you what is your national regulation telling you to put in the label? I believe that would be a good answer to share and good reference to follow