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food contact packaging
food contact packaging
food contact packaging

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:

  1. What certification should packaging manufacturers hold?

  2. What should we be looking for on the specifications or certificates?

  3. 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:
  • ISO 9001:2008
  • IFS PACsecure
  • FSSC 2000
  • 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

Quality

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.

Application

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.

europe-151606_640In 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.

FSA Guidance Document

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:

Legal Requirements

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

america-1298749_640In 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:

http://www.fda.gov/Food/IngredientsPackagingLabeling/PackagingFCS/RegulatoryStatusFoodContactMaterial/default.htm#cfr174

australia-28586_640In Australia there is a Food Standards Code for articles and materials that come into contact with food:

https://www.legislation.gov.au/Details/F2008B00620

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.

Thanks Kassy

20 Comments

  • Sheilla Vargas says:

    Hi Kassy,

    For how long is migration test cert valid? How often should we request supplier for migration testing?

    regards,
    sheilla

    • Kassy Marsh says:

      Hi Sheilla

      Lovely to hear from you!

      As far as I know there are no set and hard rules for this. However, if the material that the supplier is using does not change and the application that you’re using it for does not change (the migration test is carried out under the same conditions as the agreed application), then the certificate would remain valid.

      At the point of any changes, then it would need re-confirming through another test.

      I hope that makes sense.

      Thanks
      Kassy

  • Clem Griffiths says:

    Is there a typo on the clause reference for the template? Should that be 3.6.2?

    • Kassy Marsh says:

      Hi Clem!

      Thanks for your comment, no there isn’t a typo on the clause reference. The reference is from the packaging standard and is also our reference for our template shared for this form. If you use the template for your own records please feel free to give it your own unique reference.

      Thanks
      Kassy

  • Clem Griffiths says:

    No problem. Thanks

  • Sharon Tomlinson says:

    Hi Kassy,
    this was very interesting to read. I work in food packaging and we have BRC (for food packaging V5) I was wondering if you had a forum like this for that standard please?

    • Kassy Marsh says:

      Hi, we only have one forum – which has mainly focused on food manufacturing topics, however, I’d like to expand this and cover all food related topics such as BRC packaging, BRC agents and brokers and BRC storage and distribution. So, it would be worthwhile you signing up – so you don’t miss any articles that may be applicable for you in the future!

  • Beth says:

    Thank you for this, it’s very helpful. Are there any government approved/accredited recommended or standardly used agencies in the U.K. that perform the migration testing on packaging materials please? Or does it even matter where the testing is performed and approval given? Could it be anywhere in the EU? I’m trying to start a small (from home) business selling hand made beeswax wraps (an all natural reusable alternative to plastic cling wrap) but am finding it hard to establish how other beeswax wraps businesses have come to the conclusion that the wraps are safe to come into contact with food. I haven’t seen any with the usual certifications, the ones you outlined at the top of the page – so I’m groping in the dark as to how to know how to obtain the approvals. I’ve come to the conclusion that instead of asking each supplier of each of the components/ingredients of the wraps for ‘declarations of compliance’, that I should instead perhaps just create the finished product and have it tested as a whole, and hopefully it passes as safe. I think many assume that since the ingredients are natural it must be safe but I still need to comply with regulations if I intend to sell at market. Thanks for any further help or direction or advice you can provide on this matter.

    • Kassy Marsh says:

      Hi, wow what an interesting question! The regulations only apply to plastic based materials, so beeswax (I don’t think I need to double-triple check) doesn’t count for migration testing. Let me look into this for you and I’ll email you directly.
      Thanks
      Kassy

      • Kate Chalmer says:

        Hi Kassy, I’d also like the answer to the beeswax question please! Could you point me in the right direction of how to proceed? I make beeswax wraps for home use using cotton, beeswax, jojoba oil and pine resin and I’ve been approached to sell them commercially but I’m struggling to wade through the legislation!

        • Kassy Marsh says:

          Hi, no problem. Here is what I found…

          So, the regs (which require migration testing) are there to make sure that the chemicals from the material (that comes into contact with food) does not migrate into the food. This is typically from chemicals used to make plastic etc.

          As you’re using beeswax, I don’t think this is really the right regs to be looking at. Beeswax is an additive used in food – it has a designated E number: E901. Therefore you’re allowed to put beeswax in food. (on a side note, some countries see it as a possible allergen).

          The FSA have guidance on additives and they have not specified a maximum limit for the addition into food, therefore I would suggest that you’re ok to use it and you don’t need any testing.

          Here’s the guidance: https://www.food.gov.uk/sites/default/files/media/document/food-additives-legislation-guidance-to-compliance.pdf

  • Olivier says:

    Hi, I’ve read the above post about the beeswax wrap fabrication and legislation, and I have to say I’m a bit confuse.
    Correct me if I’m wrong, but from what I’ve read while doing some research about food contact packaging, in Europe, manufacturers must comply with the regulation EC N°1935/2004 which set migration tests, tracability and labeling “food contact” symbol.

    Also manufacturers must craft their product according the Good Manufacturing Pratices (GMP).

    Those Beeswax wrap are now commercialized by many companies within Europe and worldwide, and it seems none of them, at least the European ones, respect the EC N1932/2004, since none of them label the food contact symbol on their product.
    Do all those companies ignore this fact or is there something I’m missing?

    Beeswax wrap are made from 100% natural components : 100% cotton certified GOTS or Oeko Tex100, organic jojoba oil, pine resin or dammar gum, which are all harmless for the human body of course. But in case of authority controls, is it really legitimate to commercialize it without any certification?

    Does the fact that those Beeswax wrap are made from 100% natural components make them not covered by any EU reglementation texts?

    Also the EU N°10/2011 set directives about additives used on plastic intended to come into contact with food, is there an official EU reglementation about textiles?

    Concerning the Good Manufacturing Practices, Is this a mandatory certificate that manufacturer have to get, or more a guideline that manufacturers must comply with?

    Anyway, great article Kassy, and if you could give us more informations about the specific product (Beeswax wrap) taht would be great!

    Thanks for your time.

    Best regards,

    Olivier.

    • Kassy Marsh says:

      Hi Olivier,
      Beeswax is quite specific and I think it warrants the need for a specific article. I’ll add it to my list to write about, as we’ve had quite a few requests for this recently.
      Look out for an article coming soon!
      Thanks
      Kassy

      • Jo-Ann Clark says:

        HI Kassy, this seems like a hot topic and I am also looking for clarity on what we need to do to be able to legally sell our wraps. looking forward to your article!

        Jo

        • Kassy Marsh says:

          Hi Jo, it definitely is! In preparation for the new release of the packaging standard, I’m going to be focusing completely on packaging. I think I need to get this done as part of it! Sorry it’s taking me so long, I have such a long to do list! Kassy

        • Vicky Jones says:

          Hi Everyone, I too am searching for the legalities of making and selling beeswax wraps. I am a beekeeper and trying to add wraps to my associated products for my beekeeping craft stall. Are there any clear answers yet please? Hopeful you can help. Vicky

  • Asif says:

    Hi , could you advice where I can get pizza box sample tested to make sure it’s upto fsa standard or approval. I’m looking at importing from Turkey the factory claims its products are upto fsa standards. But I need to be sure.
    A little direction would be highly appreciated.
    I’m based in West Yorkshire any testing lab nearby would be ideal.

    Best Regards

    Asif.

    • Kassy Marsh says:

      Hi Asif
      We normally recommend ALS as they have labs all over the country and can do most tests. You will need to tell them what you want testing though. The material that the box is made from needs to be suitable for food use, so the supplier will need to tell you this. The lab can test to see if there is any chemical migration for you. There isn’t really any such thing as ‘FSA approval’ of packaging I’m afraid. It just needs to meet the regulations.
      Thanks
      Kassy

  • Manuel Maier says:

    Hello Kassy,

    Great Article, thanks for your work. Do you know when you will have time for the bee wax article?

    My best regards
    Manuel

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