Supplier Regulatory Compliance

Aligned with SQF Code Edition 9 – System Element 2.4.2

Requirement Overview

According to SQF Code Edition 9, System Element 2.4.2 requires:

“Suppliers shall comply with applicable food safety legislation relevant to the materials supplied.”

This ensures that all suppliers provide materials compliant with applicable local and international food safety regulations.

Disclaimer: This article is for educational purposes only and is not affiliated with or endorsed by the Safe Quality Food Institute (SQFI). For official SQF documentation, visit www.sqfi.com.

Key Compliance Objectives

  • ✓ Verify that all suppliers comply with relevant food safety laws

    ✓ Track regulations by country and material type

    ✓ Maintain documentation of certificates and compliance proofs

    ✓ Monitor supplier compliance status on an ongoing basis

Step-by-Step Implementation Guide

1. Develop a Regulatory Compliance Verification Process

  • Essential Components:

    • • Supplier Declarations confirming adherence to applicable laws

      • Change Monitoring system for regulatory updates (FDA, USDA, CFIA, EU, etc.)

      • Material Risk Assessments based on origin, composition, and intended use

    Evidence to Maintain:

    • • Regulatory compliance procedure

      • Signed supplier declarations and attestations

      • Notes from monitoring regulatory changes

2. Implement Verification Methods Based on Risk Level

  • Scenario Criteria:

Material Type Verification Method Frequency
High-risk raw materials Certification + lab testing Annual
Packaging materials Migration testing + FDA/EU compliance certificates Biennial
Processing aids GRAS status verification or equivalent review Upon change

  • Evidence to Maintain:

    • • Verified documentation logs

      • Certificates, test results, and safety data

      • Regulatory source references (where applicable)

3. Address Non-Compliant Suppliers

  • Escalation Steps:

    • 1. Immediately hold or quarantine affected material

      2. Conduct a regulatory gap assessment

      3. Require a corrective action plan

      4. Re-verify supplier compliance before reinstatement

    Evidence to Maintain:

    • • Non-compliance incident reports

      • CAPA documents with root cause and preventive measures

      • Final re-approval documentation

4. Train Staff and Suppliers

  • Training Scope Should Include:

    • • Procurement and QA teams: How to identify regulatory red flags

      • Suppliers: Clear expectations around your compliance requirements

      • Internal stakeholders: Risks of regulatory non-compliance
    Evidence to Maintain:

    • • Staff training records

      • Supplier acknowledgment forms

      • Training materials and refresher schedules

Common Audit Findings & Recommended Fixes

Audit Finding Recommended Action
Expired or missing certifications Use automated alerts or dashboards to track expiry dates
No GRAS status for additives Document GRAS eligibility or request supporting evidence
Import documents not validated Implement international trade compliance procedures
Suppliers unaware of requirements Provide documented expectations and refresher training

Auditor’s Checklist for SQF 2.4.2 Compliance

Auditors typically verify:

  • • Supplier files with updated compliance documentation

    • Certification validity (GFSI, FDA, EU, etc.)

    • Risk-based assessment and verification procedures

    • Records of non-compliance resolution

    • Team understanding of regulatory compliance roles

Implementation Roadmap

Build Your Program

  • ✓ Create a documented regulatory verification SOP

    ✓ Identify material categories and compliance risks

Supplier Onboarding & Evaluation

  • ✓ Collect declarations, certifications, and supporting documents

    ✓ Verify accuracy and relevance for each jurisdiction

Monitor & Enforce Compliance

  • ✓ Conduct quarterly or annual reviews of documents

    ✓ Reassess suppliers when regulations or risks change

Train & Maintain

  • ✓ Educate staff and suppliers on your regulatory standards

    ✓ Schedule periodic updates and system effectiveness reviews

Why This Matters?

A proactive regulatory compliance system:

  • ✓ Ensures legal market access

    ✓ Minimizes recall and enforcement risks

    ✓ Demonstrates due diligence during audits

    ✓ Strengthens trust in your supplier network

Need Support Building or Auditing Your Regulatory Compliance Program?

Food Safety Systems provides:

  • ✓ Regulatory compliance SOP templates

    ✓ Supplier verification and documentation tools

    ✓ Training modules for procurement and QA teams

    ✓ Audit-prep checklists for regulatory traceability

GET STARTED NOW

This document is for internal training and compliance use only. It is not affiliated with or endorsed by the Safe Quality Food Institute (SQFI).

Please refer to www.sqfi.com for official certification requirements.