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During the Women in Flavor and Fragrance Commerce/National Association of Flavors and Food Ingredient Systems joint seminar on food safety and supply chain, John Cox (John H. Cox PLLC) spoke about origin of ingredients and safety. Bottom line, he said, flavor houses are not legally required to disclose the origin of their materials. Supply chain is part of a company’s competitive advantage, its intellectual property. Companies are responsible for protecting that property. The fact remains, however, that companies are tasked with fielding customer requests without offense while defending its trade secrets. Cox detailed a number of possible limited disclosures, including statements such as “All flavor ingredients contained in this product are approved for use in a regulation of the US Food and Drug Administration,” to more detailed disclosures such as chemical class: “Contains aromatic compounds including those identical to those found in essential oils and extracts, sulfur compounds, organic acids, ketones, aldehydes and products like these.” Cox also noted that companies with the intellectual property must take care to craft any non-disclosure agreements with customers.
Meanwhile, Pamela Smith (McCormick) discussed the regulatory implications of sourcing materials. She warned that certain source countries may not have the same standards of identity for raw materials as those in the developed world. Knowing one’s supplier well is crucial, said Smith, citing the example of sodium benzoate produced by a Chinese firm that stored the petroleum-derived material in the same barrels that had once stored the starter material.
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