What was the starting point?
A project led by growers, an export ambition, and a sanitary file nobody had opened yet. This is a composite case study: it brings together situations met in the field without describing a real company. Names, volumes and dates are deliberately left out.
A company set up by date growers and traders in the province of Errachidia, in the Drâa-Tafilalet region, has for years sorted its dates under a shed for local markets. It decides to build a packing unit: receipt of dates from the growers, sorting, cleaning, grading, packing in punnets and cartons, storage, dispatch. A European importer has said it is interested, on condition that it audits the site before placing any order. A second project, a date paste, is mentioned for later.
The initial diagnostic came down to four findings:
- no sanitary title for the existing activity, although Law 28-07 requires authorisation or approval before any site starts operating;
- a mistaken belief: “since we export, we need an approval”;
- architect’s plans drawn for the building permit, with no flows at all;
- no written link between each lot and the growers who had delivered it.
Approval or authorisation: how was the regime settled?
By reading the texts before drawing, then asking the right service. For a plant like this one, ONSSA (Office National de Sécurité Sanitaire des Produits Alimentaires), Morocco’s national food safety office, issues one of two sanitary titles: sanitary approval (agrément) for the activities listed in the annex to Decree 2-10-473, sanitary authorisation (autorisation) for all others. Export is not a criterion: under Article 4 of the decree, only the activity decides, according to the categories in the annex.
Source | What it says | Consequence for the unit |
|---|---|---|
Annex to Decree 2-10-473 | For plant products, approval covers juices and nectars, seed oils, heat-treated vegetable preserves and wine products | Dates are not mentioned |
Joint Order 2768-12, codes subject to authorisation | “Fresh plant products”: treatment, packing, storage | A possible code if the dates are described as a fresh product |
Joint Order 2768-12, codes subject to approval | Fruit and vegetable preserves include the treatment and packing of dried or dehydrated fruit | A possible code if the dates are described as dried fruit |
Date paste project | “Plant-based spreads” appear among the authorisation codes, heat-treated preserves among the approval categories | Regime to be studied separately, depending on the process chosen |
Management took two decisions. First, describe the product and the process precisely in the technical data sheet, and put the question to the province’s plant products control service before filing; procedure code CP 05 gives its contact details by province. That service, which issues the licence, is the one that decides between the two codes. Second, build the manual to the level of a HACCP own-check programme, whatever the regime: it covers what an authorisation manual asks for, what an approval requires and what the importer would ask for anyway. The date paste project was taken out of scope: a new line is prepared as a new activity.
How were the site and the file prepared?
By reworking the plans before the structural work. The architect had drawn a building that was right for the building permit, but not for Article 32 of the decree. Three corrections changed the project:
- a separate entrance for raw dates and exit for cartons, for a forward flow with no backtracking and a dirty area distinct from the clean area;
- a room for packaging and a closed room for cleaning products, instead of a shared store;
- changing rooms separated by gender, sized for the harvest-season headcount, and toilets with no opening onto the packing hall.
The technical data sheet was written with the production manager: nature of the activity, site utilities, areas, sanitary description of the premises and equipment, headcount and seasonal nature, products, origin of the dates, packaging, flow diagrams, capacities, transport. The seasonal nature is not a detail: CP 05 provides for suspension of a site that stops for more than six months, except for seasonal activities.
For the manual, the team checked the list of approved good practice guides published by ONSSA. It includes a guide for the fresh fruit sector (Order 2775-21 of 25 October 2021), whose content is not published with the order. Without knowing its exact scope, the team built the manual on Articles 32 and 33 of the decree and on HACCP principles. The team’s hazard analysis covered insects and infestation, foreign bodies, contamination through water and handling, and residues of products used in the orchards.
That last point led to a change in purchasing. Law 28-07 (Article 15) requires producers of primary plant products to keep a register of production inputs, including the chemicals used; the decree (Article 47) requires the processor to make sure of the origin of what it accepts. The unit now asks each grower for this register and gives every delivery a lot number.
How did the sanitary inspection visits go?
In two stages. Once the file was filed and the receipt issued, the visit date was set by mutual agreement, within the 45 days the decree allows after a compliant file. The committee found three deviations, notified by letter within the 15 working days:
Report heading | Deviation found | Correction |
|---|---|---|
Premises and ancillary rooms | Openings without insect screens | Removable screens fitted, easy to clean, as Article 32 requires |
Design and layout | Assembled cartons stored temporarily near cleaning products | Cartons returned to the packaging room, access to the cleaning room restricted |
Traceability documents | A procedure that could not trace a carton back to the grower | Lot number recorded at receipt and carried onto the cartons, traceability exercise documented |
The operator then notified the provincial service in writing. The second visit, carried out under the same conditions, was favourable. The number issued follows Article 13 of the decree: activity code, 17 for the province of Errachidia, receipt number, last two digits of the year. It is printed on the cartons, as Article 14 requires. The register of regular sanitary inspections, on the template in Order 1063-15, was opened on the first day.
How did the unit pass the importer’s audit?
By presenting a single system, regulatory and commercial at once. For each shipment, ONSSA’s export control procedure requires the exporter to provide a certification request, a product presentation sheet, the packing list, the invoice, test reports from ONSSA laboratories or laboratories it approves, label specimens, a copy of the establishment’s authorisation or approval and the requirements of the destination country. The unit prepared a template file for each destination.
The importer’s technical team then audited the site. It checked that the sanitary number appeared on the list published by ONSSA with the right address and the right activity, read the register of visits, reviewed the hazard analysis, picked a carton at random and traced it back to the grower, then asked for the registers of two growers. It concluded with one request: a roadmap to a GFSI-recognised certification, IFS Food or BRCGS depending on the retailers it supplies. How to prepare for such an audit is covered in our article on preparing for a supplier audit, and the choice of standard in which food safety certification to choose for export.
What lessons for another food plant?
Three lessons apply equally to a fruit packhouse, an oil mill or a spice packer. The regime is decided by the activity described, not by the target market: read the decree’s annex and the activity codes, then ask the provincial service. Plans are corrected before the structural work, not after the visit. And a manual built on HACCP from the start serves three times: for ONSSA, for the buyer, then for the certification auditor.
The full framework is in our ONSSA sanitary authorisation guide, and the documents and the visit in our ONSSA approval application file checklist.