Product Authenticity, Claims & Chain of Custody Procedure

Assess authenticity vulnerability using competent, current information

Vulnerability assessments are assigned to competent technical or quality personnel with knowledge of food-fraud risks, the site’s raw materials and supply chains, and vulnerability-assessment principles. The procedure requires recognised sources of supply-chain intelligence to inform the assessment, including supplier communications, industry alerts, regulatory notifications and published scientific or technical information.

Every food raw material, or defined group of raw materials, is covered by a documented vulnerability assessment. The assessment considers historical evidence of substitution or adulteration, economic factors, ease of access through the supply chain, the ability of routine testing to identify adulterants and the nature of the raw material. Relevant scientific and technical developments, industry guidance and emerging authenticity risks are also incorporated.

The completed assessment generates a documented vulnerability assessment plan defining the controls for the materials assessed. Where the assessment identifies a need for enhanced supplier-approval controls, sampling or testing, those measures are implemented through the Supplier & Raw Material Approval and Performance Monitoring Procedure rather than being treated as separate controls within this document.

Keep the vulnerability plan aligned with changing risk

Technical Management is responsible for maintaining the vulnerability assessment plan as a current reflection of adulteration and substitution risk. A formal review is required at least annually, with additional review when raw materials or suppliers change, when new information or an emerging authenticity risk may alter the risk position, or following a significant product-safety incident involving the authenticity of the site’s products or raw materials.

Each review ends with a defined decision: retain the existing plan where the assessed risk and controls remain suitable, or update it where the risk position has changed. This preserves the distinction between a review trigger and a requirement to change the plan.

Apply assurance and testing where vulnerability warrants it

For raw materials identified as being at particular risk of adulteration or substitution, the vulnerability assessment plan defines the controls required to address those risks. Where applicable, this can include assurance processes and testing.

The procedure therefore ties additional authenticity controls to the documented vulnerability assessment rather than applying the same level of intervention to every material.

Substantiate claims that depend on raw-material status

Where a finished-pack claim depends on raw-material status, Technical or Quality personnel verify the status of each applicable raw-material batch before product release. The procedure recognises claim categories including specific provenance or origin, breed or varietal, assured status, GMO status, identity preserved status and named trademarked ingredients.

Purchasing records, raw-material usage and packing evidence remain linked to the claim so Technical Management can confirm that the finished-product claim is supported by the relevant raw-material status. Purchasing maintains the supporting records, while Production maintains traceability of raw-material usage through the controls defined in the Traceability Procedure.

Mass balance provides a further check for claims dependent on raw-material status. Documented mass balance tests compare raw-material usage with finished-product output, with the frequency meeting any applicable certification-scheme requirement or, where no scheme-specific frequency applies, at least one test every six months.

Control production-method and product-design claims

Production-method claims are supported through maintained certification status. Before such a claim is used, Technical Management verifies that the certification is current, valid and applicable to the product and process.

Where product design enables a claim, the procedure requires the claim to be substantiated before application to product. The formulation, production process and applicable legal requirements for the intended country of sale are considered: the NPD Manager develops and assesses the formulation through the Product Design & Development Procedure, Technical Management reviews and approves the formulation, Operations ensures the process is capable of consistently delivering the required characteristics, and Technical Management verifies the implemented process and claim basis.

Use process flows to identify risks to claim integrity

Products carrying claims are included within documented process-flow diagrams with enough detail to evaluate where those claims could be affected. The HACCP Food Safety Team ensures the relevant stages are represented, while Technical or Quality personnel, supported by Operations Management, identify points where contamination or loss of identity could affect the claim.

Technical Management then establishes controls based on that process-flow evaluation. Construction and verification of the process-flow diagrams themselves remain governed by the dedicated HACCP process-flow procedures, preserving a clear boundary between this procedure’s claim-integrity requirements and the supporting HACCP documentation controls.

Allocate responsibility across authenticity and claim control

Senior Management provides the resources and organisational support needed for vulnerability assessment, authenticity controls and claim substantiation. Technical or Quality Management owns the vulnerability assessment system, plan review, higher-risk material controls, claim substantiation, certification status and process-flow claim controls.

Procurement supports claim evidence through purchasing records and current approved specifications. Production or Operations maintains traceability of raw-material usage and operates processes in a way that maintains claim integrity. The HACCP Food Safety Team ensures claimed products are represented in process flows and contributes to identification of claim risks, while employees are required to follow the established controls and report concerns relating to authenticity, claims or loss of identity.

This allocation connects technical assessment, purchasing evidence, production traceability and process understanding without collapsing the separate responsibilities defined by the procedure.

Connect authenticity controls with the wider FSQMS

The procedure interfaces with supplier and raw-material approval, traceability, product design and development, product labelling and artwork control, HACCP process-flow construction and verification, document control, record control and training and competence.

Together, those interfaces support the procedure’s central purpose: to provide a documented control framework for assessing authenticity vulnerability, applying risk-based controls and maintaining evidence for the claims made about raw materials and finished products.