With a new emphasis on import safety and the transfer of legal accountability to importers, a Certificate of Analysis is not just for customers… Never was!
Traditionally used by importers to make sure customers’ requirements were satisfied
Benefit not only customers, but importers and suppliers equally
Only as good as the information used to develop them
Require samples, sampler, labs and laboratory practices to be unquestionably solid
With shipments from avocado to ziti continuously arriving at any number of ports around the country, how is it possible to know that the product in port is, not only what you ordered, but what will make your customer and the Law happy?
There are two ways to take this on. One way is to put your trust (and your marbles) in the hands of a foreign supplier whose facility you likely have never seen, and react when a problem shows up at the port, or even better, when a customer complains. Alternatively, you can test each lot for safety, quality, and fitness before the product is ever loaded for shipment, and get those results in a Certificate of Analysis (C of A). A C of A can be the key to improving product quality, safeguarding consumer safety and assuring customer satisfaction. It’s not just for covering your assets!
An entire transaction can often be accepted or rejected based upon a C of A—they are very important. At the same time, a single snapshot captured by a C of A cannot tell the complete story of a supplier’s manufacturing practices and does not reflect the reality of variability in manufacturing. The information in a C of A also exists on the edge of inconsequential. Crazy, huh! A C of A can only provide a a flash of perspective. Its validity only extends as far as the lot for which it is taken. In addition, a C of A is only as good as the sample it is based on, the sampler who took it, and the lab that tests it. For these reasons, it is imperative that an importer everything within its control to ensure that the C of A associated with its product is the very best it can be.
From the foodguys World Headquarters in Wilsonville, Oregon, what can you do to improve the reliability and value of the C of A attached to a product waiting to be shipped on the other side of the world?
According to the FDA, “A responsible importer will develop a trustworthy C of A with meaningful information that accurately reflects the product covered by the C of A.” In order to meet the expectations of our most important critic, when developing a C of A, a reliable importer will:
Establish with the customer thorough and realistic requirements based on science, safety regulations and customer expectations;
Ensure that the supplier not only has ability and capacity to produce the product, but that it unquestionably will manufacture the product to established specifications (trustworthy); and
Take responsibility for the quality and safety of the product by randomly conducting its own tests of products imported into the U.S. and measure the results against the specifications established by its customer, by itself, and by the law.
Since a C of A is both essential and unpredictable, we will take up the three steps to developing a relevant C of A in the upcoming weeks, beginning with: Obtaining Defensible Samples aka Addressing Thorough and Realistic Requirements. Exciting!
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