When a Supplier Changes Something

Across every certified plant, one finding outnumbers all the others: an ingredient on site that is not on the approved list. It is almost never anyone being careless. The usual sequence is that the regular supplier was out of stock, purchasing sourced an equivalent, production ran it, and nobody thought it was the kind of thing anyone needed to hear about.

From a purchasing standpoint it was equivalent. From a kashrus standpoint it may not have been remotely equivalent, and the reason is worth understanding rather than just complying with.

Why "the same thing" is often not the same thing

Two materials can meet the identical specification and differ completely in kashrus status, because status is determined by things a specification does not describe:

• What it was made from. Glycerin, stearates, mono- and diglycerides, enzymes and emulsifiers all perform the same function whether animal- or vegetable-derived. The spec sheet is silent on which.
• What it was made on. An ingredient produced on shared equipment carries that equipment's history with it, into your product.
• What is carrying it. A flavour, a colour or a vitamin premix is a formulation in its own right, and its carrier may be dairy or grape-derived even where the active is neither.
• Where it was made. The same material from a different plant of the same supplier is a different question.

None of those show up in a receiving inspection, which is precisely why the substitution feels invisible from inside the plant.

The part that makes it expensive

If an unapproved ingredient is found before it is used, it is paperwork. Once it has run, the question becomes what happened to the product — and the answer depends on the quantity, whether it was heated, what else was on the line, and whether the material is the kind that can be disregarded at all.

Several things that people assume will rescue the situation do not:

• Small proportions are not automatically fine. Where a substance was added deliberately to do a job in the formulation — to flavour, colour, stabilise — it is performing that function, and something doing its job has not been nullified whatever the ratio.
• You cannot decide after the fact to dilute it. Deliberately nullifying a prohibition is not permitted, and a certifier cannot approve a process whose purpose is to do so.
• An easy alternative closes the argument. Where there was a straightforward way to avoid the problem, the result is not treated as unintentional even where nobody intended it.

What actually prevents it

This is a purchasing-controls problem more than a kashrus one, and plants that solve it do the same four things.

1. Approved-supplier lists live in purchasing, not in the quality file. The person who sources the substitute at four o'clock on a Friday has to be able to see that it needs approval, at that moment, in the system they are actually using.
2. Approve alternates in advance. For every material you might realistically need to substitute, get a second and third source approved while nothing is urgent. This removes the pressure that causes the problem.
3. Treat a plant change by your supplier as a new material. Same company, same code, different facility is a change. Ask your suppliers to tell you; most will if asked, and almost none will volunteer it.
4. Make one person the owner. Certifications that stay clean have a named person who receives every formulation and supplier change. Where it is nobody's job, it is done by whoever is free.

If it has already happened

Say so, promptly, and do not move the product. The difference between a call made the same day and a finding at the next inspection is usually the difference between a contained question and an uncontained one.

Nobody is going to be surprised. This is the most common thing that happens in certified plants.

See also shared equipment and what actually transfers.