Allergen evidence from a Chinese food factory
Obtain a signed product specification, compound-ingredient breakdowns, supplier allergen declarations, shared-line risk assessments, cleaning evidence and a written change-notification agreement. Match these records to the recipe, label and batch before release. Arrange factory evidence checks with Cambridge China Bridge.
Start with a product-specific evidence file
Ask for a dated specification naming the product, recipe revision, manufacturing site and responsible technical contact. Keep intentionally used allergens separate from possible accidental cross-contact. Request supporting ingredient declarations and a signed explanation of any blank or unknown entries. A general factory certificate does not answer these product-specific questions.
For prepacked food, FSA guidance says allergens must be emphasised whenever they appear in the ingredients list. Compare the proposed label with the approved recipe and ingredient specifications. Resolve discrepancies before approving packaging.
Unpack compound ingredients
Request the constituent ingredients of sauces, seasoning blends, fillings, coatings and other compound ingredients. Ask for the original supplier specification alongside the factory’s translation. Include additives, carriers and processing aids in your questions, and ask which remain in the finished food. Terms such as flavouring or seasoning need supporting detail for your assessment.
For each purchased ingredient, record its supplier, specification revision, declared allergenic ingredients and any precautionary warning. Ask for the reason behind that warning. If a supplier withholds a proprietary recipe, seek confidential technical review rather than accepting an unsupported allergen declaration.
Map shared lines and cross-contact routes
Ask which allergens are handled at the site and which share your product’s equipment, utensils, storage or packing area. Request a process flow and a product-specific risk assessment covering ingredient receipt, weighing, mixing, rework and packing. Include airborne powders, staff movement and shared transport containers in the questions.
FSA guidance treats precautionary labelling as an assessment decision: use it only for a real cross-contact risk that cannot be removed. Ask the factory to connect each proposed warning to an identified route, the controls applied and the remaining risk. Sharing premises alone is insufficient evidence for your label decision.
Check whether the controls work
Obtain segregation procedures, production scheduling rules, cleaning instructions and completed changeover records for the relevant line. Ask how difficult equipment surfaces are reached, who checks the clean and what happens after a failed check. Request staff training records and evidence that rework stays within the approved allergen profile.
Ask a competent food technical reviewer whether the cleaning validation and any sampling address the actual allergen, equipment and product. A negative sample does not establish that every production run is controlled. Use the guide to factory cleaning validation for the wider cleaning review.
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Agree change notification and batch release
Agree written notification before changes to ingredients, ingredient suppliers, recipes, processing aids, production sites, shared-line products, cleaning or packaging. Name the factory contact and your approval contact. Require an explanation of the allergen impact, revised documents and the affected batches. Apply the approval workflow in factory material substitutions.
Before release, reconcile the batch’s ingredient records, recipe revision, changeover checks and actual packaging with the approved evidence file. Hold release while allergen questions remain unresolved. Link the records using factory-to-customer batch traceability, so changed and unchanged stock can be distinguished.
Frequently asked questions
Is a factory allergen declaration enough?
Use it as a starting point. Request ingredient specifications, compound-ingredient details, the shared-line assessment and evidence that the stated controls operate on your product’s line.
Does a shared line mean I need a may contain label?
Assess the actual route and controls. FSA guidance recommends precautionary labelling only after assessment identifies a real cross-contact risk that cannot be removed.
Can an allergen test replace cleaning evidence?
Keep both where testing is appropriate. Ask what the sample represents, which allergen was tested and whether the method suits the food. Review the cleaning and production records alongside the result.
What allergen changes should a factory report?
Agree notification before ingredient, supplier, recipe, site, shared-line, cleaning or packaging changes. Request revised evidence, affected batch identities and approval before changed production proceeds.