What you need to know about product packaging

• The standards.
• The requirements.
• BRCGS Food Safety Issue 9.

The standards

This article is written to meet the following sections of the Standards:

The requirements

Packaging design

The packaging and dispatch pack configuration, must be designed to:

• Meet the finished product specification.
• Meet any functional requirements.
• Be suitable for the application of use.
• Not pose a risk of contamination (e.g. in process packaging must be of sufficient gauge and colour).
• Consider recycled content.

When sourcing packaging, the use of application must be assessed, to ensure that the packaging is suitable for use. For example, that it is suitable for:

• Hot filling.
• Freezing.
• Suitable for oven or microwave.
• Any compositional characteristics such as high fat or pH.
• Modified atmosphere packing.
• Storage and distribution conditions.

It is the responsibility of the supplier to provide this information and the company, to check it is suitable for use in their application.

Design validation

The design must be validated under worst-case situations, and this may include assessment of:

• Transit trial results.
• Product assessment results (e.g. for functional requirement).
• Assessment of packaging specifications and statements of compliance.
• An up-to-date schematic diagram of the packaging system with key safety control points.
• Specification and instructions for use of any cooling media.
• Product-loading arrangement.
• The validation must be reviewed:
• At least annually.
• When there are any changes.
• Following a recall or withdrawal.

Statement of compliance/ Specification

For packaging supplied, documentation must be available which provides the following details:

• A statement that the packaging is suitable for food use.
• The nature of the materials used in the manufacture of the packaging.
• Confirmation that the packaging meets relevant legal requirements.
• Results of migration tests.
• The inclusion of any post-consumer recycled materials.
• The intended application of the packaging and any limitations of use, e.g. temperature ranges.
• The useable life of the packaging, for biodegradable packaging.
• A list of the pieces of legislation that the packaging has been designed to comply with.
• Date of issue of the document and if needed an expiry date.

Statement of compliance

Such documents are known as packaging specifications and/or statement of compliance. The documents can be compiled for groups of products, where the contained information is the same.

The purpose of the documentation is to provide:

• An agreement between the supplier and customer of the packaging specification.
• Details of what legislation the packaging has been designed to comply with.
• Enough information for the customer to establish if the packaging meets their design requirements.

It is the responsibility of the supplier to ensure that the documentation is accurate and kept up-to-date.  The information must be reviewed at a frequency based on risk. Evidence of the review must be recorded.

The documentation must be compiled by the supplier, by a suitably competent person, to make sure it is sufficiently detailed and accurate. The documentation must be reviewed by the customer, by a suitably competent person, so they understand the information provided and it’s suitability.

BRCGS Food Safety Issue 9

5.5.1  This clause has been updated to ensure that where packaging is moving to a new supplier, that the details of the current packaging are shared with the new supplier. This is to ensure that the new packaging is fit for purpose.

The clause has also been updated to include recycled materials or reusable materials as part of the information that must be specified.

An addition to the interpretation of this clause provides additional examples for the type of characteristics that must be considered – recycled materials and compatibility between packaging items.

The choice of packaging must also consider supply-chain requirements.

The interpretation implies that a process is needed, which will be used when sourcing packaging, for example checking of a declaration of compliance. Therefore, this should be included in the procedure.