5 replies to this topic

[krissykokoski]

Hi all,

 

  I work for a coffee company, and we are utilizing a broker to import our green coffee beans.  With green coffee beans being a raw agricultural commodity, I understand there are no clear cut requirements for FSVP.  

 

My question is - as a company, we should know what farms/suppliers the broker is procuring the green coffee beans from correct? That is how I did it while managing other supplier approval programs in pet food while using brokers.  My operations team is saying the broker is the supplier and that's where it ends, I do not agree.  

 

Thanks in advance! :) 

 

[TimG]

Mmm..So, in both Sugar and Honey, I did not know the farms/apiaries the actual product comes from. In sugar, I didn't even know much besides 'we buy it in lots' from the broker. The End. Which sounds very similar to what you are dealing with in coffee. Have you established (and have it detailed in your FSP) that you are handling the FS/Q risks with this ingredient in your facility?

The chance you are going to get a broker to give up who they get their product from overseas is pretty close to 0.

Edit-Here's a wall of text that might help direct you to the actual FSVP rules you might be able to use. Here's the link, but the wall of text below is some of the pertinent info Frequently Asked Questions on FSMA | FDA. No, I'm not going to make the wall of text pretty, I got crap to do today :P

 

FSVP Rule FSVP.4 Will importers find themselves having to meet the provisions in the FSVP regulations and the regulations on preventive controls for human and animal foods? Importers are only subject to the preventive controls rules if they are also facilities that manufacture, process, pack or hold food. An importer that is a facility can be deemed in compliance with most aspects of FSVP if it is:  in compliance with the supply-chain program requirements in the preventive controls rules;  itself implementing preventive controls to significantly minimize or prevent hazards in accordance with the requirements in the preventive controls rules; or  not required to implement a preventive control under the preventive controls regulations in certain specified circumstances (for instance, because its customer will significantly minimize or prevent the identified hazard and the facility complies with the requirements related to relying on customers to significantly minimize or prevent hazards.) FSVP.9. What if no hazards requiring a control are identified for a particular food? There may be many circumstances in which an importer evaluates the known and reasonably foreseeable hazards in a food and determines that there are no hazards requiring control. In these cases, the importer would not be required to conduct a supplier evaluation or determine what foreign supplier verification and related activities to conduct and would not be required to conduct such activities. Examples of foods for which there might not be hazards requiring controls include salt, many kinds of crackers, many cookies and many types of candy (such as hard candy, fudge, maple candy, taffy and toffee), bread, dried pasta, honey, molasses, sugar, syrup, soft drinks and certain jams, jellies and preserves

Edited by TimG, Today, 03:15 PM.

[krissykokoski]

Thank you.

 

Yes - we clean and roast the beans at our facility.  

 

As I mentioned in my past, I've had no issues getting the supply locations from a broker, but they were not for a raw agricultural commodity.  

[kconf]

As long as the broker meets your requirements, it can be considered your supplier and it ends there. 

 

Your broker can be sending you all the regulatory docs related to the products such as country of origin, COAs, etc. As long as you are maintaining records of what is in your inventory (must match labels) I don't see any issues.  

[acarver]

Coffee roaster here. We buy green coffee from a broker who meets FSVP requirements. I do not know more than country of origin.

[jfrey123]

I got FSVP certified this year, and (at least in my industry) brokers can be tricky:  if they aren't taking possession (buying specifically to drop ship to you as an example) or aren't performing the types of checks required by FSVP, then FDA will hold you liable for FSVP duties as you're marked as the consignee on the import paperwork.  From Tim's post #2 link:  "definition of the term “importer” is the “U.S. owner or consignee” of an article of food offered for import into the U.S.   This is the person in the United States who, at the time of entry of an article of food into the United States, either owns the food, has purchased the food, or has agreed in writing to purchase the food."

 

My company is in a similar area hard to navigate, where we import raw agricultural commodities (fruits and veg), but we process and modify from the original form into products that are no longer considered raw ag.  This is done under a PC plan that covers the foreseeable hazards and should mostly satisfy the requirements of FSVP.  As you state you're cleaning and roasting the beans at your facility, I think having your PC acknowledge the hazards that come from the farm level and how they're addressed within your plant would be sufficient (or "mostly satisfies the requirements" as the FDA likes to broadly state everywhere).