Documenting Intermediate Products and the Group 2 Designation
By Rabbi Akiva Tendler
Every OU Kosher certified company maintains a Schedule A through which the OU informs it of which ingredients are approved to be used in kosher products. It also lists other important information such as possible restricted sources, kosher symbol requirements, transportation methods, dairy/pareve status, etc. Schedule A also enables the OU inspector to properly audit your facility. Ingredients that he finds at your facility listed on your Schedule A as approved for production may be maintained, while other ingredients are flagged and submitted to the OU corporate office for review by the ingredient department. The ingredient department makes every effort to approve the new ingredients as soon as possible.
Each plant also has a Schedule B which is a list of brand names and product names that have been approved to bear the kosher symbol. The schedule B also lists the correct kosher symbol that should be applied to each product such as OU or OU-D.
Finally, there is another category — let’s call it “Intermediate Products.” How then should these intermediate products be managed? While the component raw materials are approved, when the inspector sees the intermediate product he will not find it listed on Schedule A.
For example, a company that produces egg rolls may prepare a liquor by mixing Yellow #5 powder with water. This yellow liquor is then added to the egg roll dough for color. Although the Yellow #5 powder is an approved ingredient on Schedule A, the liquor mix is not listed on Schedule A. In addition, there may not even be a label declaring what this liquid is.
The issue can be resolved as per the image below.
The intermediate yellow liquor product can be entered on Schedule B with the words “Intermediate Product.” You will also note in the above image that the product is not required to carry an OU symbol. This is due to its classification as a Group 2 . This option may be available for all your products and you may discuss this option with your rabbinic coordinator at the OU New York office.
When applying for the Schedule B entry, you may choose to list this intermediate product as “Confidential.” This prevents it from being listed in the Universal Kosher Data Base and is only visible to your company and the OU.
Once the intermediate product is properly listed on Schedule B, it may then added to your Schedule A as an approved ingredient. This, of course, requires proper identification on the jug so that the inspector can identify it as the approved intermediate product.
Other instances when a company would use the intermediate product designation include intermediate spice blends, starters, slurries or fillings.
If intermediate products are shipped between facilities, they must be listed on the Schedule B of the supplying facility and the Schedule A of the receiving facility. A packaged intermediate product would have a regular kosher letter, either requiring a kosher symbol (Group 3) or possibly not (Group 2), while a bulk intermediate product would have a bulk kosher letter. And again, both can be listed as confidential. (The image to the left below shows a packaged intermediate spice blend which is required to carry a kosher symbol and the image to the right shows a bulk (group 4) intermediate product.)
Rabbi Akiva Tendler serves as OU Kosher rabbinic coordinator serving the oil, tea and beverage industries. He is a frequent contributor to BTUS.