We live in a global economy where raw materials are sourced from all over the world. Food manufacturers are dependent on international suppliers and any changes in the availability of supplies result in supply chain disruption. This ranges from a simple delay in receiving raw materials to a total disruption where the raw materials are completely unavailable. Disruption affects the company’s ability to be able to supply products efficiently and may prompt them to reformulate a product because it is difficult or impossible to obtain the raw materials or in rare cases, it may force the company to discontinue a product.
The art of providing high-level kosher certification is predicated on being attuned to the unique challenges of the food industry and the implications for kashrus. This includes an understanding of both the pertinent aspects of Jewish law and the myriad aspects of food manufacturing, from equipment and packaging to food science and processes. Over the 20 plus years of tutelage I received from my esteemed father-in-law, Rabbi Don Yoel Levy OB”M, I learned the importance of spending time in the field. Rabbi Levy understood that this was the best way to learn the nuances of the industry and I can safely say that I learn most about the industry through my visits to the facilities I oversee. This is the reason that, in addition to the regular unannounced mashgiach visits, all Rabbinic Coordinators at the OK visit the factories we certify annually.
Through seeing the bigger picture and being well informed, kashrus agencies design a kosher program customized to address the needs of the customer and maintain a high level of kashrus within the confines of Halacha. Part of this is staying ahead of the curve and addressing challenges even before they arise by creating contingency plans. After all, a chain is only as strong as its weakest link, and while kosher certification works best in a climate of stability, we do have to be prepared for shifts in the marketplace and have strong measures in place to counterbalance the ripple effects. Jewish Law teaches that one must practice heightened vigilance and awareness in an environment where there is an incentive for changes to occur. Thanks to our preparation and contingency plans the current supply chain crises caused by the COVID-19 pandemic did not come as a surprise to experienced kashrus agencies.
Generally speaking, the current supply chain issues stem from two intertwined factors. The first is that a large amount of the raw materials used to produce food and packaging are sourced from huge manufacturers overseas which were severely short-staffed due to the pandemic. This led to a shortage of the basic ingredients their customers need to produce end-use products and product packaging. The other major factor is that the shipping companies (both ships and container suppliers), off loaders, and import officials, especially on the West Coast of the United States, experienced staff shortages and shutdowns. The shortage of raw materials and the shipping delays created the perfect storm for large-scale supply change disruption.
When you have supply chain issues it understandably has an impact on kashrus because companies need to change some, many, or all aspects of the way they operate. As a kashrus agency, we need to ascertain what those changes are and ensure they are implemented in congruence with the kosher program in place. Changes might include larger quantities of raw material being stored, longer, shorter, or less frequent production shifts, different suppliers than usual, changes in packaging, and reformulation of ingredients, which could result in the product changing from pareve to dairy and vice versa, or even from kosher to non-kosher.
Some suppliers will have an easier time providing raw materials due to buying power, geographic location, and proximity to their suppliers. When there is a supply chain disruption, companies will still try to source their ingredients from their usual suppliers but if they can’t, then they will need to look elsewhere, especially since an alternate supplier of an existing ingredient is far more preferable than having to reformulate. From a kosher perspective, the challenge is ensuring that the alternate supplier has an acceptable kosher certification. To make this easier, we encourage our customers to have alternate suppliers preapproved by the OK in advance to allow for more seamless flexibility.
When an ingredient is not available from a different supplier, a company may have to use a compatible (alternate) ingredient, which may change the status of the product from pareve to dairy or vice versa, or from kosher certified to non-kosher. In such cases, the company may prefer to temporarily stop production rather than have a change in kashrus status.
Some companies are handling the supply disruption by purchasing in different quantities, including switching from packaged to bulk shipments. The kashrus agency needs to be aware of new bulk shipments to ensure the transport itself is properly kosher certified. Some companies are getting larger shipments less frequently, which may require outside warehouse space. The kashrus agency may need to visit the warehouse to ensure all incoming raw materials are properly labeled and in compliance with their kosher letter restrictions.
The availability of raw materials used to make food packaging has also been affected by COVID-19 and many packaging manufacturers have had to either narrow their product line to bestsellers or packaging made from material that is more readily available, limit the purchased quantity per customer to keep distribution more equitable, and sometimes a combination of the above. These packaging changes or shortages can force the food companies to adjust their product offerings as well.
When consumer products are reformulated, this product label needs to be updated to accurately reflect the new information. This could be as simple as package size, but also complex as a change from pareve to dairy, from kosher certified to non-certified or even non-kosher, and from allergen- free to allergenic. As a kashrus agency, we train our customers to submit artwork for all new and revised labels for review to make sure they accurately reflect the kosher status. Consumers should always look for kosher symbols, but it is especially important during supply chain disruption since the status of some familiar certified products may have changed.
Many companies are experiencing staff shortages due to the pandemic and are adjusting their production schedules in myriad ways, including longer, less frequent shifts, or cutting down on the number of production days during the week. Especially in cases where the companies are getting larger quantities of raw material, they may increase their production shifts to ensure that the raw materials are processed as quickly as possible to prevent spoilage. Mashgichim need to be aware of the hours during which their facilities operate so they can conduct surprise inspection visits at all hours of operation. If companies are open later than usual, mashgichim will include evening and night visits in their inspection plan.
No matter the difficulties facing the food industry, our mission as a kashrus agency is to meet the challenges in an efficient, systemic, and kosher-friendly manner. As a rabbi, it is an honor to be part of the kashrus world and to help bring kosher food to consumers all over the world. The Torah teaches us that we are supposed to view times of struggle and challenges as opportunities for personal growth and the development of inner strength. This, in a microcosm, is the concept of Yetzias Mitzrayim – going beyond meytzarim (limitations). Since the times of Yetzias Mitzrayim, the month of Nissan has become a time of Geulah, and it is our fervent wish that we also merit the coming of Moshiach speedily in these days.