As food companies are constantly looking for ways to control food safety risks, they increasingly recognize the need to ensure that their processes are fully validated and verified on an ongoing basis to be doing what they are supposed to do to control risk. They realize that they must control environmental risk and especially allergen risk.
New regulations, the global food supply chain, changing science, consumer expectations, the Internet-enabled speed with which illnesses are reported and other factors all play a role on equipment upgrades.
For different products, manufacturers may fill the role of an exclusive distributor, a contract manufacturing organization, or a repackager. Each of these would be treated differently under the California law with respect to pedigree origination and updating.