Keep a nonconforming bulk tea lot on hold until one authorised decision owner has defined the failure, its affected scope and legal status, then approved a documented disposition: release, controlled rework or relabelling, alternative lawful use, return, destruction, or withdrawal/recall. A second test, price allowance or supplier promise does not by itself make the tea conforming.
Define the failure before choosing the remedy
“Nonconforming” only means that evidence does not match a requirement. The requirement and the consequence still need classification. A cup-profile miss against an approved sample is different from an exceeded legal limit; a torn outer carton is different from a wet food-contact liner; a typographical label error is different from an undeclared ingredient. Combining them under one red status encourages improvised decisions.
Open the investigation from the original bulk tea purchase specification. Quote the criterion, method, unit, sample identity and result exactly. If the requirement was never written clearly, record that commercial gap instead of manufacturing a retrospective limit.
Build one disposition control sheet
| Field | Evidence to record | Decision question |
|---|---|---|
| Lot and status | Supplier/buyer lot, packs, mass, location, hold label and system block | Can any affected stock move or be consumed accidentally? |
| Failure statement | Requirement, actual result/observation, method, unit, date and reporter | What exactly failed, without assuming a cause? |
| Affected scope | Sample basis, damaged-unit map, production links, split shipments and related lots | Does the evidence support the proposed boundary? |
| Decision layer | Safety, legality, identity/claim, packaging, commercial quality or document gap | Which authority and rule control the outcome? |
| Distribution status | On site, in transit, at a processor, sold onward or available to consumers | Is internal hold still enough, or is withdrawal/recall evaluation required? |
| Proposed action | Release, relabel, repack, sort, blend, process, alternate use, return or destroy | Will the action actually remove the failure without creating another one? |
| Verification | Validated procedure, representative sample, test/inspection plan and acceptance rule | What evidence will prove the completed lot is acceptable? |
| Authority and closure | Approver, regulatory/customer permission, quantity reconciliation, final status and cause action | Who may close the hold, and where did every unit go? |
Use an eight-step disposition method
1. Freeze the physical and digital lot
Apply the arrival hold workflow to every identified pack and system quantity. Stop repacking, blending, extraction, sale and sample dispatch. Protect the lot from moisture, pests, odours, mix-ups and label loss while the decision is open.
2. Write a neutral failure statement
Use “result 7.2% moisture by method X against contract maximum 7.0%,” not “supplier sent wet tea.” Record uncertainty, damaged packs or missing documents separately. Review the COA evidence boundary before treating a report as proof about the whole lot.
3. Determine the affected scope
A failing composite may implicate the defined lot; one stained bag may initially implicate that unit and similarly exposed neighbours. Neither assumption is universal. Preserve photographs, seals, transport records and controlled retained samples. If more testing is justified, prewrite a representative sampling plan that can answer the scope question.
4. Classify the decision layer
Ask whether the issue concerns food safety, a binding destination rule, product identity or claim, food-contact integrity, buyer quality, or evidence completeness. One event can occupy several layers. A commercial allowance can settle an appearance defect, but it cannot authorise unsafe food or erase a mandatory label, residue or identity requirement.
5. Check where the tea has gone
Reconcile received, sampled, repacked, processed, shipped and remaining quantities. If the tea has left immediate control, activate the lot traceability and recall map. Under current EU food law, an operator that has reason to believe food it handled is not compliant with food-safety requirements must initiate withdrawal when it has left that operator's immediate control and inform the competent authorities; consumer recall can follow when necessary.
6. Compare only feasible disposition paths
| Path | Use only when | Required proof before closure |
|---|---|---|
| Release as conforming | The original evidence was invalid or the lot actually meets every applicable criterion | Documented technical review; no averaging away or convenient sample substitution |
| Release by authorised concession | The deviation is purely contractual/commercial and law, safety, identity and customer commitments remain satisfied | Named buyer approval, scope, revised value/terms and no misleading description |
| Relabel or repack | The defect is confined to correctable information or packaging and product integrity is demonstrated | Approved artwork/pack, controlled execution, count reconciliation and inspection |
| Sort, blend or process | The method is lawful, technically justified and validated for the specific failure; traceability is maintained | Process record plus representative post-action evidence against the finished-lot criteria |
| Alternative use | The proposed food or non-food route is lawful, suitable and accepted by every responsible operator | Written destination/use approval, truthful identity, traceability and prevention of diversion |
| Return or destroy | Conformity cannot be demonstrated, action is unsafe/illegal/impractical, or the contract selects this remedy | Authorisation, transport or destruction evidence, and final mass balance |
| Withdraw or recall | Potentially unsafe food has left control or destination rules otherwise require market action | Regulatory/customer communication, recipient reconciliation, effectiveness checks and secure returned stock |
For U.S. facilities subject to 21 CFR Part 117, section 117.80 requires rework to be identified and protected from contamination. It permits reconditioning adulterated food only when appropriate and when an effective method has been proven, with re-examination before incorporation into other food where specified. Section 117.150 separately requires affected food to be evaluated for safety and kept from commerce when the operator cannot ensure it is not adulterated or allergen-misbranded. These are legal controls for covered operations, not a universal permission to repair tea.
7. Verify the completed action
Do not reuse the failing sample as proof of the modified lot. Define the new lot identity, action record, sampling locations, methods, decision rule and approver. Recheck any attribute the action could change: for example, sorting can alter grade distribution, blending can alter identity and analytical results, and repacking can create label or foreign-material risks.
8. Close quantity, cause and contract actions
Account for all kilograms and packs across release, hold, samples, return, destruction and any new lot. Record the root cause separately from the disposition: fixing this tea does not prevent recurrence. Use the quality-claim and remedy checklist for notice, evidence, costs and supplier action without allowing a commercial settlement to substitute for the technical release decision.
Keep requirement layers separate
- Legal requirement: applicable food-safety, composition, labelling, import and waste rules bind the responsible operator and may reserve decisions to a competent authority.
- Voluntary standard: Codex or a certification scheme can structure corrective action but is not automatically destination law.
- Trade reference: words such as rework, reconditioning, concession and rejection vary by business; define them in the procedure.
- Buyer specification: states measurable acceptance criteria and the evidence needed after any permitted action.
- Contract requirement: allocates authority, notice, timing, costs, title, return and remedies. It cannot authorise unsafe or misleading food.
Common buyer mistakes
- Releasing on a passing retest without investigating why results differ.
- Blending a failing lot with good tea merely to average a number below a limit.
- Assuming drying, sieving, relabelling or repacking repairs every kind of failure.
- Applying a price discount to a safety, legal or identity problem.
- Changing the lot code and losing the original genealogy.
- Testing only a visibly good portion after sorting damaged packs.
- Starting rework before the method, authority and acceptance rule are approved.
- Ignoring customers that already received part of the implicated lot.
- Closing the case without reconciling quantities and destroyed or returned stock.
- Correcting the product while leaving the process cause unchanged.
Practical conclusion
A defensible disposition file answers six questions: what failed, what stock is affected, which requirement controls, where the tea has gone, which action can demonstrably remove the failure, and who has authority to release or remove it. Keep the lot on hold until those answers and the final quantity reconciliation are complete. To define a supply programme before the first deviation occurs, send Yunjing Tea your destination, specification, packing format and proposed disposition authority.
Sources checked 11 September 2026: Codex CXC 1-1969, General Principles of Food Hygiene, 2022 revision / 2023 edition; 21 CFR 117.80 and 21 CFR 117.150, eCFR Title 21 current through 9 September 2026; Regulation (EC) No 178/2002, consolidated version of 1 January 2026; and FDA CPG 160.700, Reconditioning of Foods Adulterated Under section 402(a)(4). Recheck the destination rule and consult the competent authority where required before acting on a real lot.
