Idolene, would you know if the paper supplier would be obligated to disclose the papers ingredients?
I am in the same industry and am facing excatly the same questions. As a corrugate box manufacturer, firstly I need to establish whether my corrugate container is serving as a primary/ secondary or tertiary packaging to my customer. once this is established, it is easy to assess what type of material will be use to make the box, this spec will appear on my works order, and need not appaer on the actual HACCP
We have done the HACCP
flow chart for each process. on the left of the process we have identified all the inputs (raw material / inks/ glue / specs/ stereos/ tooling etc) and on the right of the chart the outputs (WIP / waste / effluent / FG).when doing your risk analysis you will identify direct and indirect food grade customers requirements and address their requirements through verification of your specs/ works orders. I am assuming you work fo a kraft paper mill. We request the paper mills to give us coc's, technical data sheets and aks them for their chemical and recycle contenet breakdowns. you will have to include the grades of waste and chemicals/ additives as your input and coc's/ tests analsyis as an output. Most mills comply with EU standards and have the required tests results. Where you are supplying food grade board you will have to get the mill to breakdown the grade of recycled waste (k1 /k2/ k3) and the legal % of recycle content accepted within your country, to produce the paper.
hope this helps.