HACCP Plan for Ingredient Resale / Distribution

We are an SQF certified facility for manufacturing of essential oils. Our HACCP plan covers all of our incoming oils, blending / distillation, packaging and labelling followed by distribution (1 PC and 1 CCP at filtration step). We would like to start reselling some of our products without filtering and packaging them (only opening to take a sample). 

I would like some advice on how to incorporate this into my current HACCP plan. Do I treat the products for re-sale as an incomining RM (even though I have already done this since they are the same RMs as we use in our production) or do I treat this as a processing step? My last option would be to have a separate HACCP plan for reselling/distribution, but I am trying to keep it as simple as possible. My first thought is that I will have to apply a supply-chain preventive control to these products. 

What are your thoughts?

Located in Canada but exporting into the US so FSMA does apply.  

Do not treat this as a processing step. You would just add this to your flow from receiving to shipping (essentially you're just cross docking) so the only hazards would be those you've already addressed. You do however, need to revise form 1 and 2. 

I think your supply chain PC idea works just fine

Dear Audrey,

Just note that you're removing 2 crucial steps. Maybe you wouldn't like, that your customer find what's normally removed.

Please, think we'll about the tamperproof-ness of this new variation.

The intended use should be changed. And maybe you'll need to inform about the new properties, to avoid surprises.

Kind regards,

Gerard Heerkens