By Rabbi Haim Y. Mamane – Kehilatenu 5784
A common question asked by the Pesach consumer is why we do not have a comprehensive list of approved products without kosher for Pesach certification that are “chametz-free” or “kitnyot-only.” This is indeed a valid question. So let us explain a little about the challenges involved in providing kashrut certification.
As we all know, prior to being approved as kosher, all ingredients must be carefully analyzed and approved by the MK. Once the ingredients are approved, the company is ready for an initial inspection. This involves a careful examination of all ingredients used in the production process, as well as a thorough inspection of the manufacturing facilities to ensure that the products are prepared, processed, stored, and handled according to the kashrut standards of the MK. All machinery and equipment that come into contact with the food must be formally certified as being suitable for use in the production of kosher food.
Once approved, the company is ready for production. A mashgiach is appointed to make regular unannounced visits and ensure that all the kashrut protocols are in order and up to date at all times.
Pesach certification, however, is much more complex. Aside from the finished product, any other ingredients that are processed in the same plant must be verified to ensure that they are suitable for Pesach — even if they will only be used for other products that are not certified for Pesach. Additionally, the machinery and production process must be carefully examined and analyzed to ensure that they are free from any possible cross-contamination with chametz. This enables us to be certain that the product is indeed kosher for Pesach (KFP).
Modern factories have various types of machinery, some of which are single-product or multi-product production lines. For kashrut purposes, a single-product line is simpler to certify; however, they are generally only used for high-demand products. For economic reasons, factories often prefer multi-product machinery, which enable them to produce a variety of products. Multi-product machines may be more economically practical, but they tend to introduce multiple kashrut challenges.
For this reason, when factories are not certified as KFP, either in their entirety or for specific runs, we cannot easily approve individual chametz-free products, as there are concerns of cross-contamination in the manufacturing, processing, and packaging steps. The plant must therefore be meticulously inspected and analyzed. One might wonder what could possibly be the issue with, for example, frozen vegetables. However, the consumer may not realize that vegetable companies often cook pasta using the same boilers as the vegetables, introducing a real chametz concern! A couple of years ago, a bottling company was discovered bottling yogurt and water on the same line!
Therefore, without clear knowledge that a product is being produced, processed, or packaged on a chametz-free line, we cannot consider it KFP.
Manufactured products found in stores are often composed of multiple ingredients. Many of these ingredients are also composed of further sub-ingredients, and so on and so forth. The individual ingredients used in the product’s formula are generally not all certified by the final product’s kosher certifiers. Just as consumers trust kosher certifiers, we too will trust and approve an ingredient based on certification from other hashgachot that we consider reliable. However, when it comes to Pesach, we cannot declare an ingredient certified around the year by a different hashgachah as KFP if we have no access to its formula or the manufacturing protocols of the ingredient itself or its sub-ingredients. So unless the other certifying agency is ready to confirm that the ingredient is indeed KFP, we are not in the position to assume so.
As a general rule, Pesach certification requires a mashgiach temidi to be present at all times when the products are being manufactured. The halachic requirements and protocols are detailed and complex and require a trained expert to be on site. Remember, even when a company is certified all year round, things can change. A company may substitute a Pesach-approved ingredient for another kosher ingredient that may not be Pesach-approved. A product might be verified and approved for Pesach today, but if the company and product is not regularly monitored, ingredients can be substituted that may compromise Pesach certification. For this reason, one should not rely on Pesach lists from previous years.
If this is a challenge for our very own products, all the more so when approving products certified by others. Manufacturing companies are not compelled to reveal information or even respond to other certifying agencies. Remember: a product’s formula is a company’s “secret recipe,” which they will share with no one other than their kashrut agency. So, when the other kashrut agency is not willing to take responsibility for certifying a product, we certainly cannot!
The Bottom Line
When a manufacturer requests official KFP certification for their products, we will only approve ingredients that are officially certified or approved for Pesach. However, when companies are not officially certified for Pesach, meticulous research is required to discover the source of all ingredients and sub-ingredients, as well as the facilities in which they are manufactured. Such thorough research is not always possible, as mentioned above, as companies will often be unwilling to share their exclusive formula with other companies or certifying agencies.
For generations, our parents and grandparents worked tirelessly around the clock to prepare and clean their homes from even the slightest crumb. Many chumrot and minhagim were instituted by Gedolei Yisrael to protect Klal Yisrael from, chas v’shalom, consuming even the slightest chashash chametz. We all know how challenging Pesach preparations are in a home kitchen; just imagine how complex it is in a fast-paced factory where virtually all the employees have never even heard of Pesach, let alone its kashrut protocols.
Baruch Hashem, we are blessed today to have many KFP-certified products, certainly more than our grandparents even dreamed about, and we should be grateful for this. With this in mind, may we all merit a chag Pesach kasher v’sameach!
