7 replies to this topic

[Jurate]

Hi All,

We are the manufacture of Packaging material for food stuff.
We've just had our BRC Audit two weeks ago and we've got the Non Conformance against the BRC issue 4 , paragraph 3.7.3. for not having the limitations on our Declaration of Compliance.

"3.7.3 A declaration of compliance shall be maintained, which enables users of the packaging materials to ensure compatibility with the
product with which the materials may be in contact.
The declaration of compliance shall contain as a minimum:
 the nature of the materials used in the manufacture of the packaging
 confirmation that materials meet relevant legal requirements
 the inclusion of any post-consumer recycled materials
 this shall identify any limitations of use of the declaration of compliance.
Products shall meet at least minimum legal requirements in the country of manufacture and use, where known."

We need to update our Declaration of Compliance to include the limitations, but I am very confused now, cos I am not sure what Auditor ment. by "limitations". Is that the Migration tests results for each of the finished product or is that something more general like temperature, storage, for what kind of food the packaging can be used, can be boiled or not etc.

Anybody has an idea how that should look? do anybody has a sample?

Could somebody please help me, cos I am realy stock...

Thank you.

[Rosemary4]

This is what I posted previously. We too got a major NCR for this. Our auditing body accepted this as close out.

The Company confirms that the RPET used in the manufacture of your packaging products complies with the applicable requirements of ‘Framework’ Regulation (EC) No.1935/2004 on materials and articles intended to come into contact with food and with Commission Regulation (EC) No. 2023/2006 on good manufacturing practice for materials and articles intended to come into contact with food.

Additionally RPET complies with:

• EU Regulation 10/2011/EC on plastic materials and articles intended to come into contact with food.
• Commission Regulation (EC) No. 282/2008 on recycled plastic materials and articles intended to come into contact with food.
• Packaging and Packaging Waste Directive 94/62/EC as to the heavy metal concentration levels.

Recycled content:

The film iscomposed of an A/B/A construction, virgin PET on the top and base and an innercore containing post-consumer waste. This gives an overall minimum of 50%post-consumer waste.

Intended use of packaging products: Food packaging

Limitations of use: Not suitable for conventional or microwave oven

Overall Migration: <10mg/dm²

Whilst these packaging products are not specifically designed for freezing applications, it is recommended that trials are undertaken in the customer’s own controlled environment.

Disclaimer

This Declaration of Compliance describes the status of the material used in the manufacture of your packaging products. The recipient of the packaging products is responsible for ensuring that the packaging products are tested by relevant analysis as to the suitability of the packaging products under actual conditions of use. The recipient is responsible for verifying possible interactions of the packaging products with the foodstuffs (e.g. modification of odour, taste, consistency, migration etc.).

[Jurate]

Thank you for the reply Rosemary,

Did you get the Major NC for not having the Declaration of Compliance at all or for not having limitations on it?

I find difficult to write any limitation, cos some of the materials can be used in microvave and some for freezing etc., it looks like we need to have different Declaration of Compliance for each of our product, cos it is too diffucult to compile one for all of them.

Thank you,
Jurate

This is what I posted previously. We too got a major NCR for this. Our auditing body accepted this as close out.


Additionally RPET complies with:

• EU Regulation 10/2011/EC on plastic materials and articles intended to come into contact with food.
• Commission Regulation (EC) No. 282/2008 on recycled plastic materials and articles intended to come into contact with food.
• Packaging and Packaging Waste Directive 94/62/EC as to the heavy metal concentration levels.

Recycled content:

The film iscomposed of an A/B/A construction, virgin PET on the top and base and an innercore containing post-consumer waste. This gives an overall minimum of 50%post-consumer waste.

Intended use of packaging products: Food packaging

Limitations of use: Not suitable for conventional or microwave oven

Overall Migration: <10mg/dm²

Whilst these packaging products are not specifically designed for freezing applications, it is recommended that trials are undertaken in the customer’s own controlled environment.

Disclaimer

This Declaration of Compliance describes the status of the material used in the manufacture of your packaging products. The recipient of the packaging products is responsible for ensuring that the packaging products are tested by relevant analysis as to the suitability of the packaging products under actual conditions of use. The recipient is responsible for verifying possible interactions of the packaging products with the foodstuffs (e.g. modification of odour, taste, consistency, migration etc.).

[Rosemary4]

We got it for not having one in the first place. I had got them from the suppliers but missed the fact that we needed one for our finished goods. I obtained the limitations from the plastic film manufacturers who have stated it on their declaration of compliance. Maybe a starting point for you?

[Rosemary4]

Sorry, forgot to add - yes we have had to produce one for each type of material as the different types had different limitations.

[Jurate]

Thank you Rosemary,

I've reviewed all the Suppliers Declaration of Compliance and added which material can be or can't be used for what. The problem is that not all of the Suppliers sates the limitations in their Certt of Compliance, but at least I have something and I will add more when the Suppliers update their Declarations.

Thank you very much and I hope this will suit to the BRC AUditor.

Regards, Jurate

Sorry, forgot to add - yes we have had to produce one for each type of material as the different types had different limitations.

[ozgurdemirkiran]

Hello all,

I've a question for this declaration conformity. You know you companies must have a declaration conformity article.

We are flexible converting company.

So we are producing lots of combinations of these ; PET,PE,OPP( there are lots of OPP types),ALU,PVC......... we are producing too many product types over 100.
To write a declaration corformity, we have to define material type, type of suitable food, migrations..... ect....
soo we are too many products.. how can i write a declaration conformity article? or is it possible to do this?... bec. if i try to write all structure types it will be pages and pages...

Is there any one has an idea for this?

thank you very much!....

özgür

[Jurate]

Dear ozgurdemirkiran, 

 

We are the Producer of the same as you are and the thing is that you can test the main types of the material, main suppliers, which you use and to have the Migration Tests done for the finished type of the materials which you make. It is not necessary and not practical to test absolutely everything. 

So you just say on your DOC that you have carried out the tests on different types of materials. Have a look at the attached guidelines. This is the new one and it says that you are allowed to do this. 

 

Kind Regards,

Jurate

Attached Files

•  guidance_reg-10-2011_en 28.11.2013.pdf   907.62KB   58 downloads