How to approve your food contact packaging…
Approval of food contact packaging requires different processes and an understanding of what makes food contact packaging safe. In this post we’re going to cover:
What certification should packaging manufacturers hold?
What should we be looking for on the specifications or certificates?
What testing is required?
We’ll go through each one individually. Please remember I’m only referring to food contact packaging here, so all packaging that does not actually touch the product, is not covered. Non-food contact packaging will still need approving but you don’t need to worry so much about the level of detail you go to, as there is less risk to the product.
1. What certification should packaging manufacturers hold?
There are 5 main certificates that food contact packaging manufacturers can go for:
SQF Code – Level 2
BRC Global Standard for Packaging and Packaging Materials
Out of the list above, all of them are GFSI recognised schemes, with the exception of ISO 9001. I would recommend using one of the GFSI recognised schemes to approve your food contact packaging suppliers, as the ISO 9001 standard is more of a business management standard and so, is not specifically designed to focus on good manufacturing processes of food packaging.
When checking the certificate, that you supplier provides to you, make sure:
- That the scope of the certificate includes the type of packaging that you are purchasing from the supplier
- That the relevant scope for that type of certificate is covered (e.g. production of food packaging)
How you approve your food contact packaging suppliers is up to you, as long as you have determined and documented how you are going to do it.
You could use a supplier questionnaire if you would like to approve them, and they do not hold a certificate. The questions you ask your supplier in the questionnaire however, will need to be based on good manufacturing practises for food contact packaging though, rather than food production. Make sure you check through the questionnaire when it is returned and any answers that you are not comfortable with, are actioned, before you approve them.
If you are a BRC Food Safety approved site however, you will need to ensure that you only use supplier questionnaire to approve low risk packaging suppliers, as the BRC does not allow questionnaires to be used for non-low risk suppliers.
2. What should we be looking for on the specifications or certificates?
There are a number of elements that you need to check on your packaging specifications:
That the packaging item meets the requirements that you’ve set for quality (size, thickness etc.)
That the manufacturer has designed the packaging for the application in which you are going to use it
That it conforms to legal requirements
This is fairly straight forward and is the same principle as we apply with food ingredients. The specification is part of your contact with your supplier, so it must detail all of the elements of quality and functionality that are important to you.
It is important that the supplier provides you with information about what applications are suitable for the packaging to be used in. For example, would the plastic be suitable for freezing – this is clearly important if you are going to be using it to pack frozen products. The supplier should have carried out checks on the packaging to establish what it is suitable for, and provide you with this information.
In the EU it is a packaging law requirement that every delivery of food contact packaging is accompanied by a ‘Declaration of Compliance’. This document contains key information about the packaging to ensure that it is safe for food use, such as:
- Functions or known uses (acceptable applications of the packaging)
- Storage conditions which are required to ensure that the packaging is not affected by temperature etc.
- Migration (we’ll come on to this in testing below)
- Composition (the ‘recipe’ to which the packaging is made)
- Post-consumer recycling instructions
- A declaration of compliance to the legislation in the required country(s)
It is the responsibility of the packaging manufacturer to provide the Declaration of Compliance. Therefore, it is the suppliers responsibility to establish all of the above information, and carry out the checks and tests to be able to prove it if required.
If you are using a manufacturer who does not understand how their product will perform when used in a food application (because they don’t typically make food contact packaging), and so cannot provide the information to complete the Declaration of Compliance, you are essentially accepting the responsibility of their product for them. If something was to go wrong you need to ensure that you have covered all the checks and testing on their behalf, that they would normally provide. Remember though, even if you had proved that the packaging is acceptable for your food application, your supplier will not be producing the packaging under food conditions – therefore you cannot be assured that it will be safe. I would recommend strongly in all cases, if your supplier does not understand the regulations around the production of food packaging, do not use them – find another supplier.
If you would like to find out more about the Declaration of Compliance in the EU, the FSA have created a guidance document which is really helpful, which I’ve provided below.
I also thought you might find it helpful to see our copy of the Declaration of Compliance, so you can use this as a guide, to access yours just click the button below:
There are legal requirements that you must adhere to depending on what Country you are going to sell your product. Remember, it’s not the Country that you are manufacturing the product, but where you are actually going to sell it. So, if you export product you need to understand the legislation in the Countries you export to, which can be tricky.
In the EU there a number of pieces of legislation:
Regulation EU 10/2011 Plastic materials intended to come into contact with food
Regulation England 2012/2619 Materials and articles in contact with food
Regulation EC No. 2023/ 2006 on good manufacturing practice
Directive 2007/ 42 EC relating to materials and articles made from regenerated cellulose film intended to come into contact with foodstuffs
In America the FDAs Code of Federal Regulations covers materials that come into contact with food as well. Which means that your packaging supplier needs to check if the materials that they use in the make-up (recipe) of your packaging, are allowed. The FDA provide a website to assist in this, although it is still quite complicated, where you can check each material against lists, depending on what type of packaging is being made:
In Australia there is a Food Standards Code for articles and materials that come into contact with food:
Unfortunately there is no easy way of understanding all the legislation, it requires research and time to establish if there are any specific requirements for particular Countries. In order to be able to state on the declaration of compliance that the packaging complies with the local law, the packaging manufacturer has to actually have read, understood and applied that law. Which is why, using packaging suppliers who are specialised in their field of food contact packaging is so important, as they will make it their business to understand and so will be able to advise you.
Make sure, that when you are purchasing food contact packaging, you know the legislation references for the Countries that you are exporting the product to. You then need to check that the packaging manufacturer provides you with a certificate or headed statement that says that their packaging conforms to this legislation (like the Declaration of Compliance).
3. What testing is required?
The main aim of all the regulations and requirements is to ensure that the packaging that we use, which comes into contact with the food, is safe and does not contaminate the product.
The reason why there is legislation around what materials can be used in food contact packaging, is because over time, we have come to realise that some chemicals used in the production of packaging can ‘leak’ out of the packaging and contaminate the food. Those chemicals that have been found to do this, and it has a health risk to those that then consume the food, have been banned in some Countries.
Most Countries (EU, Australia and New Zealand etc.) have therefore stated that it is law to carry out migration testing. Migration testing is a test to establish if the chemicals in the packaging, migrate (leak) into the food.
Your packaging supplier should have carried out this testing and should be able to provide you with the evidence that the packaging passed the tests.
They do not need to carry out this test for every piece of packaging that they produce, but they should be able to provide you with the test information for:
- Each type of material
- In each type of application (e.g. stored at ambient conditions, stored at freezing conditions etc.)
The testing also needs repeating each time the material or the application changes, so ensure that the migration certificate or information is up to date for the materials and applications used.
Packaging legislation is a complicated topic – it’s a bit like trying to explain the legislation around food. If there is anything that I’ve covered above that you would like explaining in more detail, please just let me know. Or if you have questions, please add them to the comments section below.
We've tagged this article as: Product packaging, Supplier and raw material approval and performance monitoring
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