Sector
Food safety for importers and wholesalers
You may not cook anything, but you are still a food business — and your customers will ask you for documentation whether or not a regulator does.
What applies to you
Importing, wholesaling and distributing food carries obligations even where nothing is manufactured. Imported food is subject to the Imported Food Control Act and the Imported Food Inspection Scheme. Labelling has to meet the Food Standards Code, including allergen declaration and country of origin. Traceability has to work one step back and one step forward.
Council accreditation usually does not apply to this kind of business. The pressure almost always comes from a customer instead — a retailer, a food service distributor or a manufacturer who wants to see a HACCP plan, a completed supplier questionnaire, or evidence against their own specification.
Plans written overseas
Where a parent company supplies the plan, it is usually built around that country's framework — FDA in the United States, EU regulation in Europe. It can be thorough and correct there and still not satisfy an Australian customer, because it cites requirements that do not apply here. That rarely means the plan is bad. It usually means it needs a local addendum rather than a rebuild.
What I do for importers, wholesalers and distributors
- Review of an existing HACCP plan against the Australia New Zealand Food Standards Code, with a written report
- A Queensland-specific addendum where a parent company owns the original document
- A food safety plan built from scratch where there is not one
- Supplier approval procedures and completed supplier questionnaires
- Labelling review — allergen declaration, country of origin, date marking
- Traceability and mock recall documentation
- Storage, receival and despatch procedures and records
- Corrective action responses when a customer raises an issue
What it costs
A fixed fee, quoted before any work starts, with travel included in the number you are given. Never an hourly rate that grows.
The scoping call is free and takes fifteen minutes. If it turns out you need something smaller than you thought, I'll tell you.
What I see go wrong
The findings that come up most often in this sector.
A plan written for another country
Thorough, well written, and citing the wrong regulatory framework. The most common reason a corporate plan gets knocked back locally — and usually fixable with a local addendum.
Nobody can amend the document
Where head office owns the plan, the local site often cannot change it. Worth establishing before work starts, because it decides whether you need a report or a supplement.
Supplier approval with no evidence behind it
A list of suppliers is not an approval programme. What is the basis for each approval, what evidence do you hold, and when does that certificate expire?
Labelling checked once and never again
A supplier changes a formulation and your label is now wrong. Without a review trigger, nobody finds out until a customer or a regulator does.
Questions
Our customer asked for a HACCP certificate. Can you provide one?
No, and nobody honest will. Certificates come from accredited certification bodies after their own audit. Often what a customer means is simply evidence of a documented plan, which is a much smaller job — worth checking before you commit to certification.
We do not manufacture. Do we really need a plan?
Not always by law, but increasingly by commerce. If a customer has asked, then you need one to keep the account, and that is a business reason rather than a regulatory one.
How fast can a review be turned around?
Most reviews come back within a week of receiving the documents. Send the plan and whatever your customer sent asking for it, and I will come back with a scope and fixed price within 24 hours.
Is our information kept confidential?
Yes. Anything you send is used only to prepare your quote and the work itself. I am happy to sign a non-disclosure agreement first if your parent company requires one.
Check it against your own situation
This page describes requirements in general terms for importers, wholesalers and distributors in Queensland. Requirements vary by council, by what you actually do, and they change. Check anything that matters against the current Food Standards Code, your licence conditions and your local council — or ask me, which is free.