Every week, surveillance networks across Europe catch microbiological contamination before it reaches vulnerable consumer shelves, but the latest Rapid Alert System for Food and Feed (RASFF) notifications highlight an ongoing vulnerability in imported ingredients. In late October, Maltese authorities notified a RASFF alert for Salmonella in a batch of tahini imported from Egypt and distributed in Spain, and the Spanish Agency for Food Safety and Nutrition (AESAN) had the product withdrawn from sale in Catalonia, Madrid and the Basque Country. While sesame paste and tahini are often treated as stable, low-moisture ambient goods, outbreaks linked to sesame-based products consistently prove that pathogens like Salmonella can survive for extended periods in high-fat, low-water-activity matrices.

When multi-country supply chains intersect with ready-to-eat ingredients, the operational implications for food manufacturers, caterers, and wholesalers are severe. For technical directors and QA managers, this alert serves as a timely prompt to examine how raw material risk assessments and supplier verification protocols handle imported seeds and pastes.

Root Cause Analysis: The Hidden Risk in Low-Moisture Ingredients

In many food manufacturing facilities, low-moisture ingredients such as sesame paste, tahini, spices, and flours receive less rigorous microbiological scrutiny than high-risk raw proteins or dairy. Technical teams often assume that roasting or processing steps eliminate microbial threats.

However, reliance on assumed kill-steps and static certificates of analysis exposes sites to significant risk:

  • Inadequate Upstream Validation: A certificate of analysis (COA) from an overseas supplier only reflects the sample tested, not necessarily the entire container load. Without validated supplier audits or periodic independent verification testing, pathogens can bypass goods-in checks.
  • Complex Multi-Country Sourcing: When seeds are harvested in one region, processed in another, and packaged elsewhere, traceability documentation can become fragmented. If a supplier cannot transparently map the supply chain back to the primary agricultural source, containment during an alert becomes slow and chaotic.
  • Cross-Contamination in Mixing and Processing: Tahini is frequently incorporated into ready-to-eat dressings, dips, and baked goods without a subsequent thermal kill-step. If contaminated sesame paste is introduced into a production line, the pathogen is distributed across large batches of finished goods.

Under BRCGS Food Safety Issue 9 (specifically Section 3.5 on Supplier and Raw Material Approval and Performance Monitoring, including the raw material risk assessment at clause 3.5.1.1, and Section 3.9 on Traceability), sites must maintain active, risk-based verification of all raw materials—particularly those sourced from high-risk origins.

Technical Guidance: 4 Audit-Tested Checkpoints to Verify Today

To ensure your facility is protected against primary raw material failures like the recent tahini alert, technical teams should review these four checkpoints immediately:

  1. Review Your Raw Material Risk Assessments (Clause 3.5.1.1): Re-examine the raw material risk assessments for all sesame, seed, and paste ingredients. Ensure that microbiological contamination, historical pathogen data and geographic origin risks are actively factored into supplier scoring, and that your HACCP plan reflects them.
  2. Challenge Your Certificate of Analysis (COA) Verification Frequency: Do not rely solely on supplier COAs. Institute a schedule of independent, accredited laboratory check-testing for high-risk ambient ingredients upon receipt.
  3. Audit Upstream Traceability and Mass Balance: Run a quick traceability test on any compound products containing sesame paste or tahini. BRCGS Issue 9 (clause 3.9.2) expects full traceability within 4 hours, but can your team trace from finished product back to the specific supplier lot and import documentation within two hours? Include a mass balance check so the quantities received, used and despatched add up.
  4. Verify Supplier Certification Standards: Confirm that your raw material suppliers hold recognised GFSI certification standards and that their HACCP systems explicitly validate controls for enteric pathogens in low-moisture foods.

Closing the Gap Before Your Next Audit

Incidents involving ambient imported ingredients demonstrate why robust supplier management and dynamic raw material risk assessments are essential to maintaining audit readiness and brand protection.

At Global Food Consultancy, we help food manufacturers, packers, and storage operators eliminate compliance blind spots through independent pre-audit gap assessments, robust raw material risk assessment and HACCP reviews, and practical technical coaching.

Don't wait for an auditor or a border alert to find the gap in your supply chain verification. Visit us at Global Food Consultancy to find out how we can support your technical team, or email hello@globalfoodconsultancy.com.