Due Dilligence

Where is the line dividing direct contact and secondary packaging. Who decides? Do apples etc. carry a natural barrier? Not everyone washes their apples before eating or cooking. Where do I stand if a customer uses our cases as primary packaging i.e. supermarket display without informing us of the purpose in advance. Are we legally bound to find this out in advance?

Not clear as to whether you are the producer of the packaging, or the supplier of the product within the packaging that may subsequently be used for other uses.
However, in both instances, my interpretation of the standard is that the category B rating (direct food contact) relates to the processes and production of the packaging itself, rather than the subsequent end use of it which, as you rightly point out, may be well out of your control further down the line.

Hope this helps.

ML

Do apples etc. carry a natural barrier? Not everyone washes their apples before eating or cooking.

No because people eat the skin of apples. Bananas I'd say have a natural barrier.

As part of the hazard analysis or HACCP study you should determine the 'intended use' for your products as far as you can and under normal circumstances. However, you cannot be expected to know all of your customers 'intended uses' and processes to the n'th degree and it is up to them to approve your material through samples / trials etc. for their particular product and process.

As long as your materials comply with relevant legislation [for intended use] and are within specification you are OK. I would say you are not legally bound to find out how a customer may use or misuse your products.

Similar to Mike really.

Regards,
Simon