3 replies to this topic

[foodeng]

The factory ı am working do not use recycled materials. BRC-IOP vers. 4 asks for to assure if not using recyled materilas. How can ı proof the materials are not recycled. How does the purchasing department evidence this subject?

[Simon]

You can only prove it by working closely with your raw materials suppliers, maybe an audit and certainly request relevant documentation, specifications and certificates.

In the old days we had certificates and statements coming out of our ears, but now suppliers should provide a comprehensive document know as a Declaration of Compliance. This document includes details of the supplier, product composition, legislation the product meets including migration results. The DoC should include a section on whether any recycled materials or post consumer waste are included in the product.

By the way you need to be supplying your own customers with a Declaration of Compliance.

You can get a fantastic template for a Declaration of Compliance from FPE Flexible Packaging Europe and they also provide an early 'heads up' and regular updates on legislation and technical advances and research in flexible packaging. I recommend you contact them and perhaps become a member. Keeping up to date with legislation is also a requirement of BRC/IOP.

FPE Flexible Packaging Europe
Am Bonneshof 5
40474 Düsseldorf
Germany

Tel: +49 (211) 4796 150
Fax: +49 (211) 4796 408
www.flexpack-europe.org

[foodeng]

Do all the raw materials should be assessed even if some of them do not come to contact with foods?

[Foodworker]

The first question is whether the products you make are plastic and for direct contact with food or other high risk product. If so, then as Simon said, you need to provide a Declaration of Compliance if you sell within the EU under EU Law.

The BRC takes this Declaration requirement a bit further. It requires that it is provided for all packaging types that come into direct contact - paper, metal, glass etc. even though it is not currently a fully implemented legal requirement.

It also requires that even if your products are not in direct contact, but the contact layer is not an absolute barrier, then your products are considered high risk and will also require a Declaration. There are other threads about the definition of an absolute barrier.

One of the statements that this Declaration must contain is whether any of the raw materials contain any post-consumer recycled materials. It does not state that they must not contain any of these materials.

The only way to be able to make this statement is to understand your suppliers processes and in reality obtain full warranties from your suppliers.

It is up to you then to evaluate the information. If there are post consumer recycled materials, you need to assess what risks there may be to consumers.

As an example, there may be problems with the use of recycled printed paper with resulting contamination of food by mineral oils.