8. Supplier management
Supplier management of agents and brokers
In this article, we look at what is required by agents and brokers, when supply materials and product to GFSI certified businesses.
Supplier approval of agents and brokers
This topic has been one of conflict over the years.
When businesses purchase materials from agents or brokers, they need to be able to approve the material – which means, that they need to gather the information required to do so.
However, agents and brokers, sometimes, don’t want to share this type of information – for fear of the customer bypassing them and going direct to their supplier (cutting out the middleman and therefore cutting the cost of the material).
BRCGS have tried to combat this by adding additional requirements into the standards.
BRCGS Food Safety Issue 9, Clause 3.5.1.5
“… the site shall know the identity of the last manufacturer or packer, or for bulk commodity products the consolidation place of the raw material.”
Interpretation of clause 3.5.1.5:
“… In this situation [where the agent/broker is GFSI certified], the requirement to approve the processor, packer or consolidator is not applicable, as the requirements of these Standards ensure that effective systems for supplier approval and traceability are in place. However, the site will still be expected to know the identity of the processor, packer or consolidator.”
BRCGS Agents and Brokers Issue 3, Clause 3.4.3
“Where required by the customer, the company shall provide information to enable the last manufacturer or processor of the product to be approved. This shall include the identity of this manufacturer or processor.”
Interpretation of clause 3.4.3
“… In most situations, this will be covered by the agent’s or broker’s certification to the Standard. Information relating to the identity of the last manufacturer or processor is also required to facilitate customers’ awareness of any issue that occurs in the supply chain.”
BRCGS Packaging Issue 7, Clause 3.6.6
“Where raw materials are purchased from companies that are not the manufacturer or packer (e.g. purchased from an agent, broker or wholesaler), the site shall know the identity of the last manufacturer or packer.”
Interpretation of clause 3.6.6
“… Where the agent or broker is certificated to the following then the site simply needs to know the identity of the manufacturer or packer supplying the raw material (i.e. the location/ company where the raw material underwent the last process other than storage or distribution): [GFSI certificates listed].
In this situation, the requirement to approve the manufacturer or packer is not applicable, as the requirements of these standards ensure that effective systems for supplier approval and traceability are in place. However, the site will still be expected to know the identity of the manufacturer or packer.”
Confusion
Many agents and brokers interpret these requirements to mean that they don’t have to declare the last manufacturer/processor to their customers, if they are certified to the BRCGS Agents and Brokers standard. This is not the case.
The agent and broker must declare who their supplier is. What they don’t have to do, is provide the information needed to approve that supplier, such as completed SAQs and certificates. This is because it’s expected that the agent or broker will obtain this information and approve the supplier. The verification of this is completed by the GFSI auditor, during the agent/brokers audit.
Conclusion
Agents and brokers – with a GFSI certificate
In order to supply businesses with a GFSI certification, agents/brokers must declare the name and address of their suppliers to their customers, even if they hold a GFSI certification for agents/brokers.
Agents and brokers – without a GFSI certificate
If, the agent/broker does not hold a GFSI certification, then they must declare all information requested by their customer, to allow the customer to approve their supplier.
Agents and brokers – supplying customers who supply UK retailers
Please note, agents and brokers who are supplying businesses who supply UK retailers will expect all information requested to be supplied. Failure to do so will result in loss of business to the agent/broker. This is because the agent/broker’s customer will not be able to complete the retailer’s finished product specifications or pass their audits without this information. Therefore, if you are an agent or broker aiming to supply businesses that serve retailers, be prepared to provide comprehensive and detailed information.
What are your thoughts?
This topic does cause non conformances at audit and it would be great to know what your experiences and thoughts are. Please add them to the comments section below.
It has surprised me over the last few years how many certified A&B’s seem unaware of their obligation to identify the supplier when asked (or at least claim to be). I had on several occasions to forward a copy of the relevant clause just to back up my request for information. In one case, the customer site had to commit in writing to the supplying A&B that they would not go direct to the supplier, and underatke if they did, to pay a penalty to the A&B. How enforceable such an agreemnt may turn out to be I don’t know. I understand some A&B reluctance to share this informationas they see it as a threat to their business, but as a customer it is frustrating. Certainly historically I have been bemused when delving into the supply chain for a number of product supplied by A&B’s, and fully support the clauses both in contributing to effetcive managment of supply chain and also in giving the customer a lever to use when requesting information….
I can completely understand why agents would not want to disclose the name of their supplier in fear of losing business to direct supply. However, that seems to be a mute point if the material is delivered to the customer with the manufacturers name on the case label. Should the site retain those labels as evidence of receipt, would this fulfil clause 3.5.1.5 of the Food Safety standard?
Hi Kassy,
thank you for the clarification. I also have had issues with agents and brokers in the past.
This will be an interesting topic with our next Audit.
Keep up the good work.
Thank you for the insightful article, Kassy. It presents clear and valuable information on a complex topic. We have encountered similar challenges with agents, and I will using this article as a reference to support our case moving forward.
Declaration of last packer or manufacturer assists in terms of specifications and supply chain risk assessment. However the agent/broker is also at risk of losing their customer to the manufacturer/packer hence want to keep their manufacturer secret. However sometimes auditors can be nitty-picky , eg I have had an NC were my supplier, a courier, had ISO 9001, ISO 14001, ISO 45000 but did not meet GFSI certification.
This is very frustrating!
We had a similar NC raised by a customer, the carrier we sent into them wasn’t GFSI – but the real twist was when the carrier told us that the retailer used them for transfers between their distribution centres.
Yet we are to believe that working to meet the published standards should ensure a fair playing field.
This is exactly what we have been experiencing. UK retailers also expect us to provide details of all sub-components’ suppliers (names and country of origin) so having GFSI certification by the direct supplier is definitely not sufficient if you are working with UK retailers.
Even when a company is GFSI certified and completed their due diligence, it is still very important for the manufacturer using this product to ensure it is safe for their application- this is mainly driven by possible allergen cross-contamination as it has been highlighted to us that there is generally a lack of understanding round this topic.
Kassi,
Many thanks for this step through. Busy food industry Tech Managers don’t always have the time to look up the various BRC standards to link up supply chain requirements – excellent job clarifying a tricky area, and definitely a help as I review my Supplier Approval scheme!
Great article, which hopefully will clarify that transparency in the supply chain that is required by the standards.