1 reply to this topic

[foodmcc]

Hi everyone,

 

I am wondering those that work strictly in distribution and storage, how much you may be involved with product label compliance?

 

I understand for traceability everything needs to be tracked.  But in terms of label compliance for products you did not manufacture, are you responsible for label accuracy?

 

I am asking because our state agency is telling us that we are responsible for things that we have no involvement in the manufacturing process.  We are simply storing and distributing.  Is anyone else in a similar situation?

[Lynx42]

Does your company own the product, or are you a 3PL?  If it's product your company purchases and owns I do not know what those requirements would be.

 

We are a 3PL and do not own any of the products in our facilities. We have a statement in one of our policies that we are not responsible for labelling as the customer retains ownership of the product while it's in our facility, and we address this in our Food Fraud Mitigation Plan. We have no responsibility for primary packaging labels.  

 

We do repack/relabel outer packaging for one customer, and we keep records of the labels and approvals for those projects only.  They are 3x5 label with the sku, product name, lot, best by dates, and the customer name that gets put in a plain brown cardboard box, but the customer retains responsibility for all the information on the actual label, we are just responsible for ensuring that the physical label printed matches the approved label they sent us. 

 

Edit...  my reading comprehension is lacking as I see the 3PL now. 

Edited by Lynx42, Yesterday, 05:09 PM.