6 replies to this topic

[Peter-Paul]

Goodmorning everyone,

I am Peter-Paul, working at a small converter for Flex. Packaging in Holland and we have implanted BRC/IoP Iss 3 in our company.
Currently we are discussing the declarations of compliance we send to our customers. What I am trying to find out if it is necessary to fysicly sign the document or not. I wrote a procedure this morning in which I state that due to safety measures our company will not send a digital document which is signed by our management. It is fairly easy to copy and paste the signature and use it for other évil'means.


In the procedure I state that the document is on the offical company format and send on from a official company email.
My question basicly: is a declaration of compliance valid without a signature of the general manager or other official.


Kind regards
Peter-Paul

[Charles.C]

Dear Peter-Paul,

Welcome to the forum!

I’m not in packaging but if by “declaration of compliance” you mean a product specification (PSP), it is my experience that BRC Food auditors expect a PSP to be mutually agreed by seller / buyer and evidenced in writing / signature (typically a GM/MD but i guess the rank is not compulsory, just convenient if claims come later ). This applies to both ingredients and finished products. It can get complicated where you are purchasing from a general distributor and not the original manufacturer.
If I hv misunderstood, it is likely that a packaging guru will soon respond more precisely.

Rgds / Charles.C

[Peter-Paul]

Morning y'all,

Charles, thank you for your answer, i have re-written the procedure and included a note that all specs need to be signed to be valid.
Enjoy tour weekend,

Peter-paul

[cazyncymru]

Hello

you can password protect your document so that bits can't be copied and pasted , and you can also put a statement on bottom or watermark saying "uncontrolled if printed".

caz x

[Foodworker]

Declarations of Compliance have specific meaning within packaging legislation, currently only applicable to plastic materials in contact with food.

I am attaching the Guidance Notes from the UK Food Standards Agency.

There is a suggested format for the Declaration which includes the provision of a signature, but I can't see anywhere that this is a legal requirement. However, it is clearly good practice.

Attached Files

•  legalcompliancefoodpackaging.pdf   446.22KB   93 downloads

[rosie]

Declarations of Compliance have specific meaning within packaging legislation, currently only applicable to plastic materials in contact with food.

I am attaching the Guidance Notes from the UK Food Standards Agency.

There is a suggested format for the Declaration which includes the provision of a signature, but I can't see anywhere that this is a legal requirement. However, it is clearly good practice.

Hi There

See attached link - schedule 4 tells you what is required by law on a DOC

http://www.legislati...ents/made<br />
Many packaging suppliers will give you overall migration limits - but some plastics will contain materials with SMLs (specific migration limits) which are not usually tested for - insist your packaging supplier tells you of any materials contained that have SMLs.

Rosie

[Charles.C]

Dear All,

Fascinating stuff although in some parts, the attachment content was somewhat of a maze to me.
As would probably be expected the situation in UK appears, like food, to be based on an interpretation of certain EC directives.
I daresay the situation in Holland is the same.

As per a previous post, I could not find any codicil in the attachments which obliges parties at both ends of the transaction to submit a signed acknowledgement of mutual understanding of what each other is buying / selling. This seems remarkable but hv to state that I cannot directly quote a specific analogous requirement in EC food directives either.

Maybe the authorities responsible for specifications simply consider it is not in their scope to educate people how to avoid contractual business conflicts due variances in quality expectations. The aspect mentioned in one of the attachments regarding use of specified (standard?) testing methodologies is an absolute minefield IMEX, even with the best of mutual intentions. Not to mention sensorial attributes.

In BRC food, the topic appears (blurred) in 3.7.2.3 –

The company shall seek formal agreement of specifications with relevant parties. Where specifications are not formally agreed then the company shall be able to demonstrate that they have taken steps to ensure formal agreement is in place.

Whatever that means!. Looks like an ISO crib.

BRC packaging I have no idea. ?.

Rgds / Charles.C