Code of Practice. Claim Validation

Transcription

1 Code of Practice Claim Validation

2 Amendments from V1 - V2 1. Introduction & Objective 2. Validation Amended and new points added 3. Claim Integrity New points added 4. Claim Approval Removed 5. Product inputs New section added 5. Approved Suppliers Removed 6. Testing Now Section 4 7. Organic Certification Removed 8. On Pack Instructions Validation (Cooking) - removed, this will form part of a new guideline Removed, this will form part of a new guideline Contents Page No. 1. Introduction & Objective 3 2. Claim Validation 4 3. Claim Integrity 4 4. Testing 4 5. Product inputs 5 Page 2 of 5

3 1. INTRODUCTION & OBJECTIVE Product claims are being extensively used to market products, and announce key attributes and benefits of products. Customers have an expectation that the claims are true, honest and transparent. These claims cannot mislead or deceive customers. For the purpose of this Code of Practice the scope covers will not cover general labelling requirements, such as cooking times and characterising ingredients. In order to ensure any claims made are true and accurate, it is essential that they are validated during the product development process and then regularly verified. The claim needs to remain valid through the entire shelf life of the product. This document supports the Supplier Excellence Program and is intended to provide further clarity and guidance on implementation of these requirements. The intention of this document is that it is not to be used in isolation but as a supplement to the full requirements of the Supplier Excellence Program (or if you have a GFSI Standard in place, to that standard). These requirements will clearly cover facility expectation, monitoring programs, equipment requirements, validation and verification. To help identify how the requirements must be met for each clause a P, R or O will be indicated under the columns headed PRO. These columns indicate whether the requirement is met through: P = Procedure. R = Record. O = Observation. - A documented procedure that has been fully implemented. - Documented and accurately completed records. - Compliance will be checked through observation. Page 3 of 5

4 P R O Section No. Requirement Compliance (Y/N add comments) R 2.0 claim Validation Where product claims are intended to be used on the product label, the following supporting documentation must be maintained to ensure accuracy: Where Certification is relevant, certificates must be held and reviewed on a minimum annual basis to verify validity (or as per relevant expiry date). Certification standards and reference material to support the validity of the systems utilised. eg Organic certification. Any supporting literature to demonstrate appropriateness of claims. Full traceability and/or chain of custody must be demonstrated and monitored as part of the Approved Supplier Program Claims based on theoretical data must be approved by the Quality Specialist and documented on the specification. Where claims are made about the methods of production (e.g. organic, Halal, Kosher) the site must maintain the necessary certification status in order to make such a claim. P R 2.1 Claim Development During development all product claims must be validated in full with formal approval from Woolworths before artwork dispatch or product launch. Claims include, but are not limited to the following Sustainability Claims e.g. Rainforest Alliance, Fair trade, Marine Stewardship Council (MSC) Nutrient Claims e.g. Gluten Free, Low Fat, Fortified etc. Country of Origin Organic / Biodynamic - Certification must be from a Woolworths Approved Certification Body Dolphin Friendly Free Range Vegetarian Ingredient Claims e.g. Natural Colours & Natural Flavours O 3. Claim Integrity The integrity of all products supplied to Woolworths Group must be guaranteed. Suppliers supplying products to Woolworths must ensure the claim status of products is maintained from raw material procurement to end of finished product shelf life. All products must be handled in a manner which prevents contamination or substitution with products which are not compatible with the certified claim standard. The process flow for the production of products where claims are made must be documented and potential areas for contamination or loss of identity identified. Appropriate controls must be established to ensure the integrity of the product claims. Claims must be re validated for any changes that may impact the on pack claim, these could include, but are not limited to, changes in raw materials, process or supplier of the raw material. Where a claim is made regarding the suitability of a food for allergy or food sensitivity sufferers, the site must ensure that the production process is fully validated to meet the stated claim and the effectiveness of the process is routinely verified. This must be documented. P R 4. Testing All analytical product claims (e.g. nutritional claims, shelf life or free from) must be tested in accordance with the COP, Microbiological and Chemical Requirements for the relevant category or claim. Page 4 of 5

5 P R 5. Product inputs Chemical testing is required to validate the organic and or any other claim status of the product, where applicable. An ongoing testing program must be developed and implemented to regularly test the claim/s are true and accurate. Product testing to verify accuracy of claims by 3rd party independent laboratory, NATA or ILAC accredited, on an annual basis. Approved claims based on theoretical data are exempt from analytical testing Where products are labelled or claims are made on finished packs which are dependent on a status of a raw material including: specific provenance or origin breed/varietal claims assured status (e.g. GlobalGAP, RSPO) genetically modified organism (GMO) status identity preserved named specific trademarked ingredients The status of each batch of the raw material must be verified. The facility must maintain purchasing records, traceability of raw material usage and final product packing records to substantiate claims. The site must undertake documented mass balance tests, for a defined period, at a frequency to meet the particular scheme requirements or at least every 12 months in the absence of a scheme-specific requirement. Page 5 of 5