Customer will not provide their ingredient recipe

Good afternoon,

I Have a question.. We produce flour tortillas for a Customer who send his mixed in bags sealed.

Since I have to work with the team in the supplier approval and Haccp analysis i was asking for the product specification of this ingredient or mixed in order to evaluate and validate .. Since the customer he provide their mix ..they don't want to provide us the recipe or list of ingredients , they think we will stolen their recipe for our products ..

Could you share with my any part of any CFR of the fda or where i can show to them that is a requirement .. 

thank you

Could you not request that they provide all the ingredients in the mix and instead of supplying each exact amount of each, provide an average range percentage?  I was formally in tortillas and had a similar situation, I did put my foot down as I stated that we needed to assess all incoming ingredients as part of the hazard analysis.  Ingredients were then provided via spec sheet and average percentages were agreed upon.  Another option is to get an NDA on file.  

Best of luck!  

You can explain the supplier about physical, chemical (including allergen, radioactive material) & biological hazard. Then ask the supplier is any hazard present in your supplied mix.

As stated, ask for a range formula, and/or NDA.

I don't know what they'd be so nervous about anyway.   Tortillas don't exactly have the kitchen sink in their bill of materials...

Regardless, a NDA should alleviate their concerns.

Yeah, they need to give you this so you can properly list the ingredients on your finished label and accurately develop your nutritional information.  Labeling for non-finished products isn't clearly spelled out in FDA guidance, but every place I've done spices that were for further processing would always label cases with the name, lot code, DOM, and ingredients in descending order on each case or tote.  That much I've always believed to be minimally required.

Not only that, but if their spec sheet doesn't list the ingredients, then it's a worthless specification.  And even if they did list ingredients but refused to provide a range for the composition of those ingredients, you cannot accurately create the nutritional information.

Seems like you need the company leaders from yours and theirs to sit in a room and hammer this one out.  In my plants, this would be a full stop problem.

You can require disclosure of the ingredients if they want you to process the material.  Without ingredients noted, you could be required to perform a MUCH more extensive cleaning before doing a changeover because of the unknown hazards, and the extra time and labor is going to be added to your service fee.  

If they are willing to pay for it, problem solved I guess.  If they aren't willing to, you need to be willing to say no to their business.

Hi, I understand they are both your supplier (mixes) and customer (tortillas). How is the finished product packed – bulk or in retail printed packaging? If in retail packaging – do they provide the packaging? Do you audit them as your supplier? I would say: supplier approval (HACCP flow, CCPs, chemical, micro, allergens, physical, radiological, GMO, RSPO, vegetarian/vegan, claims, MSDS) + list of ingredient, allergens in the mixes, other allergens that they and their suppliers handle (cross contact risk assessment) + NDA.