10 replies to this topic

[j.yang]

Hi - I'm really hoping someone can help me with this. I am from the food packaging world (flexible packaging). We provide food packaging materials to our customer who fills it with baked goods that will be sold in Canada. My customer has asked us to complete a supplier evaluation and I'm stumped on what to do.

 

Verbiage from customer's evaluation survey:

Canadian Requirements - applies to products that will be sold in Canada. Available upon request is one or more of the following evidences. Choose one.

1. Copy of "Letter of No Objection" or opinion letter for this packaging from Health Canada (HC) for this food product application.

2. Copy of formal approval letter from Canadian Food Inspection Agency (CFIA) for this material. Or give web link(s) to CFIA approval.

3. Other, please specify: 

 

As a food packaging supplier - what are my requirements to the Canada regulations?

 

 

[Charles.C]

Dear j.yang,

 

IMEX, most  producers would initially ask the customer the (accessible) origin of his requirements since this will typically also contain the related context to enable a response.

 

Unfortunately most producers are incapable of long-distance telepathy. The burden is usually on the receiver to communicate.

 

Some readers here may (luckily)  recognise yr posted contents as a standard format of known Canadian origin and point you on. Will soon know. 

 

Rgds / Charles.C

[mapry2]

Hi,

 

I am based in Canada and have good understanding of CFIA requirements. Please note if you can prove that your packaging materials do not pose any food safety risk and meets FDA norm, you should be good. You are not obliged to get letter from CFIA. FDA requirements are equivalent to CFIA requirements. If you have any letter or supporting documents from FDA, please provide those.

 

Feel free if you need any further information.

[j.yang]

Thanks! I really appreciate your help. I've obtained letters from my suppliers on FDA regulations and food safety use. I hope this will suffice our customers needs.

 

Thanks again!

[gcse-fhp]

j.yang,

You may also check the Packaging Association of Canada website. They are very likely to have the information you need, things like bi-lingual requirements, etc.

 

All the best,

gcse-fhp

[Sandima]

As mapry2 said " if you can prove that your packaging materials do not pose any food safety risk and meets FDA norm" you are fine so Option 3, meets CFR 21 (whatever the rest of the numbers are.)

 

As side note is that the CFIA is no longer doing any approvals for chemicals or packaging materials and the existing reference listing will be removed at some point in the future.  So anyone who has an approval letter will want to be sure to hang onto it.  The burden will now fall to the manufacturers of the materials to have proof that it is safe.  

[Katja]

I have to disagree, just because it is approved for FDA doesn't necessarily mean its approved in Canada.  Depending on who your auditor is and where they come from this may or may not be enough.  We request that their packaging materials meets the requirements of Division 23 of the Canadian Food and Drugs Act & Regulations. All components used to manufacture food packaging materials are part of the  "CFIA's Reference Listing  for Packaging Materials."  the list is still active, is easy to use and readily accessible, use it while you can because it will soon be obsoleteo to http://www.inspectio...ence.asp?lang=e

 Your only obligation to them is if you would like to keep them as a customer.  As someone who requests it from my suppliers i always appreciate when i get someone whoi sends me what i ask for and takes the time to do it.  I am likely to use them as a supplier next time around.

 

SQF practitioner

Edited by Katja, 15 January 2014 - 03:59 PM.

[mapry2]

Lets do not go too much in to the technicality of this and understand from the food safety requirement point of view. I am a SQF consultant and had similar situation in two of clients. We proved to the SQF auditor that food safety concerns were addressed and we were good.

[Peter Snopko]

From my understanding of your question, there are a number of things that need to be addressed;

a) GMP - You need Good Manufacturing Practices in place

b) Certified Quality System. ISO 9001:2008 no longer cuts the mustard so ISO 22000 or better yet FSSC 22000 is the way to go'.

c) Food Safety compliance for raw materials and finished item. This is a big subject, so make sure you have more than the material suppliers say so that their materials comply with US FDA CFR 21 or EU or other regs. You need test data to show banned substances are not there, other substances are within allowable limits etc. This is a specialist subject so use the likes of Smithers/Pira etc.

I am involved with a number of companies exporting food to a range of countries and many have problems in this area.

d) Purchase and finished good specifications. I have failed a number of packaging manufacturers on this one as they didn't specify what they purchased and what they sold to customers.

e) HACCP - If you are making food contact packaging materials this is a vital necessity. If printing make sure you have also included the Prepress area in the HACCP risk assessment as allergens printed on the packaging could be a CCP in the prepress area (your risk assessment should show you this).

 

Hope this helps you. Feel free to ask any questions on the above and I will see if I can help you.

Cheers from warm sunny New Zealand

Peter

[Charles.C]

Dear All,

 

As far as I understand, this is primarily a legislatory-driven question. This may be purely related to "FS" but not always exclusively IMEX.

 

From the previous posts,  it is so far unclear to myself who actually is the current controlling authority. ie who is the customer required to "negotiate" import with / and subsequently commercialise the product.

 

This was the simple logic behind my post #2.

 

Rgds / Charles.C

[j.yang]

Thanks to all who have replied. I appreciate your help!

 

We do have the following in place and are SQF Level 1 certified.

• GMP Program - employees are trained annually and a monthly verfication audits and annual validation audits are performed
• Allergen Risk Analysis and Assessment has been done. Quarterly verification audits and annual validation audits are performed.
• HACCP Risk Analysis and Assessment has been done. We have no CCPs. Quarterly verification audits and annual validation audits are performed.
• Letters and product specifications with CAS#'s are obtained from our suppliers and are confirmed to comply with US FDA CFR 21.

So far my customer is satisfied with the information I've provided. In addition, our products are listed in the Health Canada approved polymers for packaging materials.

 

http://www.hc-sc.gc....mere_tm-eng.php