Status: ✅ usable. Last updated: 2026-09-08. Benchmark for new files: China clients show the same gap profile at first cycle.
Related: case 01 · guide 02 red flags
1. The profile
| Area | Most common NCs |
|---|---|
| 1 Commitment | no socialization meeting held/planned; supervisor not registered in SIHALAL / no competency-exam pass; no internal SJPH training yet |
| 2 Materials | halal-cert-required materials lack certificates from BPJPH-acknowledged HCBs; certs from non-recognized HCBs (incl. 清真); new supplier brands unapproved; packaging/cleaning/lubricant/validation-media items not listed; no ethanol-source declarations |
| 3 Process | flowchart missing or mismatching floor; records don’t reconcile; OEM/分装 site not disclosed; canteen/shared-warehouse contamination not addressed |
| 4 Products | 配料表 hides animal/alcohol items behind collective names; khamr- or deity-evoking names; 清真 mark misused |
| 5 Monitoring | first IA/MR cycle not yet executed; no CAPA register; changes not reported |
The pattern repeats because it follows a logic rather than coincidence — the sequence below explains how these findings usually arise.
2. The typical sequence behind the NCs
- Company comes from a food-safety (SC/ISO/HACCP) culture — hygiene and records are usually fine.
- The halal-specific governance layer is new: supervisor competency, socialization, internal training → first-cycle NCs.
- Material certificates are the long pole: suppliers worldwide don’t hold BPJPH-recognized certificates; flowchart/statements take time; replacements change formulations.
- Flowchart disclosure hits trade-secret reluctance — needs NDA + staged requests.
3. Using the card
- Kickoff briefing — set expectations: “these five will likely be your first-cycle findings; here is the path.”
- Pre-audit checklist — every item on the card becomes a desk-review question (guide 02 §3).
- Benchmarking — when a new file deviates from this profile (e.g., a food-safety NC), it is worth a second look.