Do you have your product co-packed for you?
Even though you aren’t a manufacturer, traceability, authenticity and food safety is still your responsibility.
If you sell products that are manufactured by another company on your behalf, responsibility for the safety and authentication of those products resides with you. It’s your brand reputation that is at stake. It’s similar to if you were a big company with many locations; no matter where the product is physically produced, if there is a problem with one of your finished goods, it’s your problem. Even if your co-packer buys the raw materials on your behalf, and perhaps even created the recipe for you, there are two situations where you still need to manage your own risks.
The first is for food fraud. Food fraud is when a component in one of your products claims to be one ingredient, but is really something else. For example, there have been several cases of the US uncovering food fraud scams where high end ingredients such as olive oil were cut with lower end oils but still sold as olive oil. Besides false advertising, that kind of fraud can create undeclared allergen issues and the liability if a consumer is affected will come back to the company that sold the product. If your product contains ingredients from other countries, you need to be aware of the authenticity of those raw materials. Many reported cases of food fraud showed that the fraudulent ingredient was substituted in another country and the manufacturer and even the distributor may not have been aware. Certificates of analysis and testing become important parts of your risk management strategy.
The second risk you need to manage for your co-packed products is food safety. It is your company’s name on the box, not your co-packers. That means that your company reputation will be damaged if there is a recall and you will be held responsible for the consequences and costs of that recall. To mitigate and manage these risks, you need to keep track of that product, from raw materials through production and out to customers. One up and one down traceability of your own products will ensure you can react quickly in a recall situation.
New regulations for consignment
For those companies that send packaging and/or raw materials to the co-packer, you are responsible from end to end. Under the new tighter regulations, it would be wise to think of yourself as a manufacturer and set up internal record keeping systems as if you were making the product yourself. Track it, test it and be ready to recall it if any problems are found.
Isn’t that their job?
While your co-packer is no doubt committed to the safety and authenticity of the ingredients they use and the products they produce, time is of the essence in managing your brand in any recall. Technology and freedom of information means that consumers now know about suspect items about the same time businesses do, so it is incumbent upon brand owners to have all the information they need to quickly respond to concerns, recalling troubled product or reassuring consumers of its safety. Make sure it is information you have available when you need it.
If you do not own a manufacturing facility, you can still manage the manufacturing process in your own ERP system. In a system, co-packers can be set up as locations as well as suppliers. You may choose to only track from the finished good lot if the co-packer purchases raw materials on your behalf. However, you may want to have an outside lab perform tests for authenticity on some randomly selected lots if your product contains any of the high risk fraud ingredients such as honey, high end oils, fish, etc. Taking control of the manufacturing process in your own system will also give you better costs, profitability and yield reporting; information that is valuable to manage and grow your product lines and business.