1. Overview

Valid-IT is administered by Eurofins on behalf of participating retailers to control the risk of GM contamination of specified GM materials. The model used is a supply chain model where all suppliers of sensitive materials back to, but excluding, growers must be Valid-IT approved. Part of the approval process will be an assessment of control of growers to ensure Non-GM status.

Valid-IT approval does not, of itself, guarantee that any individual batch of material will not be contaminated with GM but evaluates the systems in place to minimise the risk of such contamination.

2. Scope

All retailer food products and supplements that include ingredients that are subject to control or are derived from materials subject to control fall within the scope of this policy.

Controlled ingredients are defined by the specific retailer and are currently

• Maize and products thereof
• Soya and products thereof
• Cotton Seed and products thereof
• Rapeseed Oil of Non-EU origin or derived from rape of Non-EU origin and products thereof

Processing aids, carryover additives and other substances that do not appear on the product label are excluded from the policy. These ingredients may be subject to specific control by retailer policy. Valid-IT approval is only pertinent to GM contamination and does not indicate compliance with any other relevant retailer policies. It remains the responsibility of suppliers to ensure all retailer policies are complied with.

3. Valid-IT Recognition Process

Systems

There must be a demonstrable system in place for the control of potentially GM contaminated materials. These will generally fall within 3 categories:

1. IP Certification
   A certificate and audit report from a recognised inspection body, working to an equivalent standard to a Eurofins IP audit, is provided for verification. The products seeking Valid-IT approval must be detailed within the scope of the IP audit.
2. BRC/IFS/BS Certification
   A certificate and audit report from a recognised inspection body is provided for verification. Control of IP materials must be specifically within the scope of the audit (Valid-IT materials should be subject to equivalent controls to IP materials). The products seeking Valid-IT approval must be detailed within the scope of the audit.
3. No Certification in Place
   Certification is not a requirement of the Valid-IT system but where no certification is in place documentary evidence must be provided equivalent to that which would be required for a Eurofins IP accreditation. This will include:
   • Supplier control
   • Raw material control
   • Segregation during storage
   • Process flow
   • Verification and testing regimes
   • Any other information relevant to GM control
   This process is likely to be far more time consuming than review of existing certification and as such will incur extra cost. This will be advised prior to commencement of the evaluation of evidence submitted. If submitted evidence is insufficient to provide confidence in the controls in place it may be necessary to request a 3rd party audit prior to approval. This audit will be at the applicants cost. Eurofins cannot recommend any specific audit body as this would be a conflict of interest.

Suppliers

All suppliers, except agricultural suppliers, must be listed on Valid-IT. Suppliers who are already listed on Valid-IT may be used for the supply of any materials within the scope of their listing. If your supplier is not listed on Valid-IT then you may register them as a sole supplier to you. All of the evidence required will have to be submitted on behalf of the supplier and the conditions for listing will be the same as for any other supplier. This supplier will only appear on your website entry and will not be generally available for the supply of Valid-IT materials. The cost for each sole supplier registered will be the same as that for an individual application. N.B. IP certification is not sufficient for the supply of Valid-IT materials only Valid-IT approval as this is a supply chain model.

Evidence must be available, either from audit reports or by submission, of the control of agricultural suppliers to ensure non-GM status.

Testing

The three most recent analyses, from an independent laboratory accredited for GM analysis, must be submitted with the application.

Renewal

Renewal will be required annually. The evidence submitted for renewal should be the same as that submitted for a new application as above.

Variations

Any significant changes to accreditation status or to processes that would have a significant effect on the GM status of the product must be notified to Eurofins. There is no need to inform Eurofins of any variation in suppliers if these are Valid-IT approved suppliers and the materials purchased are within the supplier scope as detailed on Valid-IT. These changes can be captured at renewal. Any non Valid-IT approved suppliers should not be used for the supply of Valid-IT materials until such time as their Valid-IT approval is completed. Where suppliers lose their Valid-IT approval you will be notified and you must cease to use these suppliers until such time as their approval is reinstated. Any incidences of non-conforming materials or product withdrawals relevant to this policy affecting your supply chain should be notified to Eurofins.

4. Alternatives

The system can be used to list alternative ingredients to Valid-IT controlled materials, e.g. sunflower lecithin instead of soya lecithin. These are not controlled materials but a listing fee will be charged where appropriate. Where alternative ingredients are produced at the same site as controlled ingredients details of the segregation procedures to ensure no crosscontamination with controlled ingredients must be provided.

5. Other Information

Website: http://www.valid-it.com
Enquiries: ValidIT@eurofins.com

1. Overview

Valid-IT is administered by Eurofins on behalf of participating retailers to control the risk of contamination of specified spices with illegal dyes. The model used is a supply chain model where all suppliers of sensitive materials back to, but excluding, growers must be Valid-IT approved.

Valid-IT approval does not, of itself, guarantee that any individual batch of material will not be contaminated with illegal dyes but evaluates the systems in place to minimise the risk of such contamination.

2. Scope

All retailer food products and supplements that include ingredients that are subject to control or are derived from materials subject to control fall within the scope of this policy.

Controlled ingredients are defined by the specific retailer and are currently

• Capsicums (Paprika, Chilli, Cayenne pepper)
• Turmeric
• Compound ingredients containing controlled spices

Fresh spices, dried and chopped spices and spice extract, including colours and oleoresins, are excluded from this policy, however please be aware that some ingredients used in the above may be subject to the Non GM policy. These ingredients may also be subject to specific control by retailer policy. Valid-IT approval is only pertinent to contamination with illegal dyes and does not indicate compliance with any other relevant retailer policies. It remains the responsibility of suppliers to ensure all retailer policies are complied with.

3. Valid-IT Recognition Process

Systems

There must be a demonstrable system in place for the control of materials potentially contaminated with illegal dyes. These will generally fall within 2 categories:

1. BRC/IFS/BS Certification
   A certificate and audit report from a recognised inspection body is provided for verification. Control of susceptible materials must be specifically within the scope of the audit.
2. No Certification in Place
   Certification is not a requirement of the Valid-IT system but where no certification is in place documentary evidence must be provided equivalent to that which would be required for an accredited audit. This will include:
   • Supplier control
   • Traceability from first grinding to finished product
   • Documented quality system
   This process is likely to be far more time consuming than review of existing certification and as such will incur extra cost. This will be advised prior to commencement of the evaluation of evidence submitted. If submitted evidence is insufficient to provide confidence in the controls in place it may be necessary to request a 3rd party audit prior to approval. This audit will be at the applicants cost. Eurofins cannot recommend any specific audit body as this would be a conflict of interest.

Suppliers

All suppliers, except agricultural suppliers or suppliers of exempt material, must be listed on Valid-IT. Suppliers who are already listed on Valid-IT may be used for the supply of any materials within the scope of their listing. If your supplier is not listed on Valid-IT then you may register them as a sole supplier to you. All of the evidence required will have to be submitted on behalf of the supplier and the conditions for listing will be the same as for any other supplier. This supplier will only appear on your website entry and will not be generally available for the supply of Valid-IT materials.. The cost for each sole supplier registered will be the same as that for an individual application.

Testing

Each batch/lot of Valid-IT material should be tested, by an accredited laboratory, for the presence of illegal dyes The three most recent of these analyses for each spice to be listed must be submitted with the application. Minimum requirements are testing for Sudan Dyes I-IV and Para Red by a recognised method. Where risk assessment dictates testing should also be carried out for the following colours, in line with Food Standards Agency Guidance:- Sudan Red B, Sudan Red 7B, Sudan Red G, Butter Yellow, Metanil Yellow, Orange G, Rhodamine B, Orange II, Toluidine Red, Annatto, Bixin and Norbixin.

Renewal

Renewal will be required annually. The evidence submitted for renewal should be the same as that submitted for a new application as above.

Variations

Any significant changes to accreditation status or to processes that would have a significant effect on the status of the product must be notified to Eurofins. There is no need to inform Eurofins of any variation in suppliers if these are Valid-IT approved suppliers and the materials purchased are within the supplier scope as detailed on Valid-IT. These changes can be captured at renewal. Any non Valid-IT approved suppliers should not be used for the supply of Valid-IT materials until such time as their Valid-IT approval is completed. Where suppliers lose their Valid-IT approval you will be notified and you must cease to use these suppliers until such time as their approval is reinstated. Any incidences of non-conforming materials or product withdrawals relevant to this policy affecting your supply chain should be notified to Eurofins.

4. Other Information

Website: http://www.valid-it.com
Enquiries: ValidIT@eurofins.com