Can anyone suggest ideas on how to meet this bullet ? 5.2.3

We are fresh-cut and distribution company for fruits and Veggies. We don't have sophisticated labelling since we mostly sell traded, repacked and fresh-cut produce. Our labels are mostly printed in house.?

Does this bullet apply to us? If so, how can I respond to its N/C ? Any suggestions?

Thanks

 

Jean-C.

little more info please

 

what exactly does that bullet say and what exactly does your non conformance say

5.2.3. Where the label information is the responsibility of a customer or a nominated third party the company shall provide information:
• to enable the label to be accurately created
• whenever a change occurs which may affect the label information. Minor Yes, currently do pack for private label but nothing I written in this section  Need to add procedure to this section

 

You just need a label creation procedure that lays out what you do re: printing labels (lot code etc) and a statement that no 3rd party or customers provide you with labels

 

Do remember that you must meet the following under SFCR

If you create labels in-house as indicated in post 1, you need to outline the procedure that you use to create them.  To Scampi's point, the procedure needs to ensure the labels meet regulatory requirements.

 

But in post 3 you mention that you do pack private label for some customers, and that gets just slightly stickier.  If you help with the raw creation of those labels, you need a procedure that shows how you do it, how you ensure they meet regulatory requirements, and how they meet customer requirements (the process for them being approved).  But if your customer provides their own private brand labels, your procedure needs to outline how you check them before use (again checking for accuracy, regulatory compliance, etc).  Document the methods you use to ensure the correct labels are used for the correct items.

 

Back in my spice days, we would grind/blend/repack spices into case size quantities for B2B sales, and we were a 3PL.  The case labels were printed in house on regular Avery half page stickers we could print ourselves, super simple look and procedure.  We'd email a word doc template to the material owners for approval (their naming, lot code, production date, distributed by info, etc).  They'd approve it via email, and that label template along with approval email went into the paper batch record.

This clause is where, for example, you're not the brand owner.

 

So perhaps you supply Loblaw with some cut produce which is labelled as Loblaw own brand?  You would need to provide the information to them so that they could create a label which was legal and representative of the product as the label is their legal responsibility (albeit you check the content as well as the previous two clauses still apply). This clause is checking your process of providing that information which would normally be via a specification I'd imagine. You also need to make sure the information is updated if something changes and have that in the procedure and a prompt in your stage and gate process to ask for approval, update if needed and plan the change.

 

If they don't get involved in that label, then the clause doesn't apply but the previous two clauses about what is on the label will still apply if it's going to be part of the consumer unit.

 

As for your printed in house labels in general, obviously you still need a process to assess them as legal anyway.  Them being printed in house often brings more risk not less.

Thanks all who replied to me; this is now solved/closed.

Jean-C.