Patrico, maybe the problem is in the translation of the standard. In English, it does not require "analysis" of the raw materials, but it requires "assessment" to establish the presence and likelihood of contamination by allergens. It has to include review of specs and getting information from suppliers, for example through questionnaires, to understand the allergen status of the raw material. This is in 5.3.1, and allows for you to determine that your raw material does not contain allergens, using just information that you can get from the supplier.
We use pulp sheets made from wood and bamboo in our products. There are no allergens in that. I have a documented risk assessment that shows how we know that there are no allergens present, and every year we have our pulp suppliers fill out a questionnaire that states that there are no allergens in their products. And I have researched and understand how their pulp sheets are manufactured., so I know that there are no allergens present.
As long as you document how you determine that there are no allergens there, you are OK.
Don't forget, that allergen management requires that you show how you protect your allergen-free raw materials from the allergens on site that your workers bring in their lunches. Part of your plan has to detail how you prevent contamination from crumbs from their meals.
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