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Decorative Packaging Query


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Simon

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Posted 20 October 2003 - 07:00 PM

We receive a lot of any enquiries through the website and most are pretty straightforward. In your opinion does this organisation need BRC/IoP Certification?
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Question:

We are a manufacturer of textile based accessories for decorative packaging such as bows, tassels, handles…

Our industrial customers are active mainly in confectionary, perfume and luxury products. Currently we are negotiating with a major-UK based manufacturer of chocolates who is anxious about the compliance of our supplies with his internal constraints on food processing and packaging.

We contacted the Food Standards Agency, Food Contact Materials Unit, but could not be helped with our problem.

In as far as there is no intentional contact between our products and the food products, there seems to be no regulatory framework on the characteristics of the products, nor on the production process we operate.

Could you help us in this matter ?
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My Condensed Answer:

Although not easily identifiable as packaging in my opinion as your product will enter a food processing environment I believe your suppliers would have to have the necessary controls in place and become certified to category A of the BRC/IoP Packaging Standard.
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What do you think?


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rheath

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Posted 22 October 2003 - 10:22 AM

I agree to an extent..

To cover all bases having certification would prevent any issues but my understanding of this enquiry is ; the tassel maker is asking if they need to be certified.

The answer to this it depends on 2 factors:

1. The confectionary customer and what level of control they wish to apply. Section 4.9.1 & 4.9.2 (I am sure there will be a similar clause within the food standard). If the confectionary customer is happy to audit and control tassel maker (provided technical systems are in place this may be OK) then BRC/IOP standard may not be required.

2. The confectionary customer supplies to retailers signed up to BRC. If product does not go to these retailers then the BRC/IOP standard is merely good practice and not required as an absolute.

Hope I've now confused issues even more. :P

Regards

Richard



Simon

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Posted 22 October 2003 - 11:14 AM

Section 4.9.1 & 4.9.2

Hi Richard,

Can you remind me what the above clauses say as I haven't got my copy to hand. I read it every night but can never remember them all.

Simon

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rheath

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Posted 22 October 2003 - 12:41 PM

Simon,

My memory is a little sketchy, I think the clauses read a little like below:

4.9.1 The company shall evaluate and select suppliers based on their ability to supply products in accordance with the company's requirements. Criteria for selection, evaluation and re-evaluation shall be established. Records of the results of evaluation and any necessary actions from evaluation shall be maintained..

4.9.2 As part of hazard assessment, and where appropriate, suppliers of materials shall be certified to this standard. Where this standard is not implemented, the company shall be responsible for ensuring that adequate technical practices are being maintained, audited and documented following hazard analysis.

Regards

Rich



Simon

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Posted 22 October 2003 - 12:53 PM

Oh those old chestnuts - cheers mate! I will try and dechiper your post now.
:D

Simon


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Simon

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Posted 22 October 2003 - 01:19 PM

Hmm?

Yes, this is the packaging standard talking about the requirements for suppliers of raw materials to packaging companies. However, The retailers require all of the packaging used on their branded food products to be produced by companies certified to The BRC/IoP Packaging Standard. With this in mind I think the decision tree looks something like this:

Are bows, tassels, handles considered as packaging?

If no, or if yes but chocolate is not retailer branded (4.9.1/4.9.2 type supplier controls will do)

If yes, and chocolate is retailer branded (supplier must be BRC/IoP Category A registered)

I think this is logical captain.

Simon


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rheath

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Posted 22 October 2003 - 01:55 PM

Perfec :D






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