COA & Certification Verification

Aligned with SQF Code Edition 9 – System Element 2.4.3

Requirement Overview

According to SQF Code Edition 9, System Element 2.4.3 requires:

“Certificates of Analysis (COAs) and food safety certifications (e.g., GFSI-recognized schemes) shall be obtained and verified for compliance with specified requirements.”

This requirement ensures that raw materials and ingredients entering your facility meet both internal specifications and external regulatory benchmarks.

Disclaimer: Food Safety Systems is not affiliated with or endorsed by the Safe Quality Food Institute (SQFI). This content is intended solely for educational and implementation purposes. Visit www.sqfi.com for official program guidance.

Key Compliance Objectives

  • Ensure 100% collection and validation of COAs for applicable materials

    Verify authenticity and scope of supplier food safety certifications

    Document a formal verification procedure

    Establish an escalation process for discrepancies

Step-by-Step Implementation Guide

1. Establish a COA and Certification Verification System

  • Include:

    • A COA Requirements Matrix by material type

      Certification acceptance criteria (e.g., GFSI-recognized schemes, USDA Organic, etc.)

      Clear verification responsibilities (e.g., receiving, QA, purchasing)
    Evidence to Maintain:

    • Documented verification SOP

      Approved materials/specifications matrix

      List of accepted certifications and verification methods

2. Implement Verification Activities

Document Type Verification Method Frequency
COA (Certificate of Analysis) Check test parameters against spec sheet Per shipment
GFSI/third-party certifications Validate on issuing body’s database + scope review Annually
Organic/NON-GMO Confirm cert and perform mass balance audit Per lot or batch

  • Evidence to Maintain:

    • Verified COAs with approval notations

      Certification review logs and renewal tracking

      Material validation reports

3. Manage Non-Conforming COAs or Certificates

  • Escalation Steps:

    • 1. Quarantine affected products

      2. Analyze variance severity (critical vs. minor)

      3. Notify supplier within 24 hours

      4. Request and document corrective actions

      5. Reapprove material post-verification

    Evidence to Maintain:

    • COA discrepancy logs

      Corrective Action Reports

      Supplier communication records

      Verification of resolution before release

4. Continuously Monitor and Review

  • Ongoing Monitoring Should Include:

    • Monthly audits of COA completeness and accuracy

      Quarterly reviews of expiring certifications

      Annual assessment of the verification process’s effectiveness

    Evidence to Maintain:

    • Internal audit reports

      Expiry tracking documents

      Verification process updates and revisions

5. Document and Review the Test

  • Documentation Requirements:

    • Full test report including all steps and findings

      Corrective/preventive actions

      Update recall SOPs based on lessons learned

    Evidence to Maintain:

    • Signed mock recall report with conclusions

      Updated recall SOP and training records

      Corrective action plan with completion tracking

Common Audit Findings & Recommended Fixes

Audit Finding Recommended Fix
Missing or incomplete COAs Implement a mandatory receipt check at receiving
Expired or invalid certificates Track expiry dates with alerts
No validation of test parameters Require QA review for COA compliance
Delayed discrepancy response Use a documented escalation timeline

Auditor’s Checklist for SQF System Element 2.4.3

Auditors typically review:

  • COA verification logs for incoming materials

    GFSI or equivalent certification validation records

    Escalation reports for any identified discrepancies

    Interviews with receiving and QA personnel regarding document review process

Implementation Roadmap

Build the Verification System

  • Draft your COA and certification verification SOP

    Set up a COA parameter checklist by product type

Train & Assign Responsibilities

  • Designate responsible parties for verification at each stage

    Train receiving, QA, and purchasing teams on how to verify properly

Monitor & Document

  • Check each COA for specification compliance

    Log certificate renewals, validations, and discrepancies

Improve and Automate

  • Use alerts for certificate expiration

    Conduct annual verification system reviews

Why This Matters?

A robust COA and certification verification process:

  • Prevents use of out-of-spec or non-compliant materials

    Minimizes risk of recalls or enforcement action

    Supports internal quality assurance standards

    Improves supply chain accountability and readiness for audits

Need Help Creating or Optimizing Your COA Verification Program?

Food Safety Systems provides:

  • COA review templates and spec matching sheets

    Certificate validation trackers and audit-ready forms

    Training modules for QA and receiving personnel

    Tools for automating expiration monitoring and discrepancy alerts