10 replies to this topic

[Franco]

Hi Saferpakers,

I think most of you are packaging manufacturers.

We are food manufacturers (spirits) and we are facing with EU Regulation 178/2002 requirements.

Art. 18 of 178/2002 states that “The traceability of food, feed, food-producing animals, and any other substance intended to be, or expected to be, incorporated into a food or feed shall be established at all stages of production, processing and distribution”.

Last week we had a meeting with the collegues of all European subsidiaries and Top Management in order to find out a common approach and we came to the point that packaging materials shall not be tracked nor traced, at least from a legal viewpoint.

My personal opinion is that traceability for primary packaging is not mandatory, but I would strongly recommend it because it may have beneficial effects on the quality of the whole supply chain.

I’m not able to express this idea in money terms.

What’s your opinion ? Do you think tracking of Packaging Materials is mandatory ? Why ? Any experience to share ? Do’s and don’ts ?

TIA. Regards. Franco

[Simon]

My personal opinion is that traceability for primary packaging is not mandatory, but I would strongly recommend it because it may have beneficial effects on the quality of the whole supply chain.

What's your opinion? Do you think tracking of Packaging Materials is mandatory? Why? Any experience to share ? Do's and don'ts ?

Hi Franco - good topic.

I agree with you that primary packaging should be part of the traceability system, whether or not it is specifically included or excluded by EU Regulation (EC) No 178/2002. And I think most customers will look to their packaging suppliers to comply as part of their overall due dilligence systems.

EU Regulation (EC) No 178/2002 applies to all food products sold in the EU and comes into effect on 01st January 2005. Although I've not read the legislation yet I did hear that packaging will count as "stage operators" and as such they will be required to keep a set of records including:

"- The identity of each input batch/item and its supplier
- The attributes of each output batch/item including the identities and characteristics of its input batches and details of its processing
- The identity of each output batch/item and its recipients - for example, transport companies on behalf of customers"

As you would expect it sounds quite complex but the requirements for traceability records are probably no more than any professional packaging company would keep especially if they are certified to The BRC/IoP Packaging Standard or similar.

e.g.
- Retention of raw material reference sample and ID label containing supplier traceability information (e.g. supplier name, batch id, date of manufacture, product code etc.)
- Retention of production / finished product samples and production documentation (details of quality checks / results, machine(s) used, operators etc.)
- Dispatch records (product label with product details, batch ID, product code, date of manufacture etc. Also pre load checks and signed delivery dockets etc.)

I've probably missed something, but you get the picture.

I do think we need to clarify officially whether the legislation applies to packaging. If anyone can clarify this I would be grateful.

Cheers,
Simon

[Charles Chew]

Legislative enforcement by the US Government some time next month will soon require food manufacturers to keep detailed records of their supply chains. This is in line with The Bio-Terrosim Act 2002 which recently required facility to register with FDA.

EU is expected to implement similar program next year.

Is supply chain traceability a matter of just good record keeping? Is it not that having a sound traceability mechanism and procedures is paramount to ensuring an effective product recovery versus monitoring activities in record keeping alone.

Food auditors have a major role to play in ensuring each facility's traceability system is effectively sufficient and must be recognised as a significant pre-requisite to certification.

Cheers

Charles Chew

[Simon]

I've merged two ongoing threads about traceability together, apologies if I have caused any confusion.

It looks like traceability and ISO 22000 are going to be the two major topics on the food safety agenda over the next year or so.

Charles, The EU Regulation (EC) No 178/2002 comes into effect on 01st January 2005 and we had a brief discussion on the subject a few days ago - see above.

Does the US legislation include packaging? Perhaps you could provide a brief overview.

Regards,
Simon

[Charles Chew]

Hi Simon,

Producing safe food is not complete until the end product is suitably PROTECTED by good packaging using suitable materials. Integrity of the product is compromised once the packaging is opened.

Franco is indeed correct to include primary packaging as part of traceability and generally, this is where information is contained to engage an effective product recovery / traceability. Primary packaging is really what we are talking here.

However, secondary packaging is equally important. Having product information on the secondary packaging (e.g. outer carton) certainly improves recovery ratio. Tertiary packaging is not an issue.

RFID is an expensive alternative to currently used bar coding and conventional prints but I am sure it has other benefits as well e.g. retail security features. It remains to be seen whether this method will be widely used.

See www.apv.invensys.com for additional information on RF Tagging.

Traceability is going to be a BIG issue world wide especially when it is designed to protect consumers against food terrorism.

Cheers
Charles Chew

[Charles Chew]

Hi Franco,

Would I be correct to say that from the stand point of a packaging material manufacturer, the production records in relations to the sales record would immediately allow you to trace to your end customers.

And, in the event of a hazard risk assessment by the manufacturer where tests indicate the packaging material to be the contributing hazard, material purchase records would be able to trace the supplier immediately.

If this situation were to occur and the respective supplier informed of the specific hazard, a recall or trace by the supplier of similar batch of materials from its other buyers is therefore possible.

However, I tend to believe that the sudden interest by the US Govt. and EU is more towards protection of the supply chain vis-a-vis food terrorism where packaging is simply part of the end product.

Cheers
Charles Chew

[idtrack]

Hi,

I am picking up on an old discussion, but on browsing the forum I see that the question has been asked whether food packaging materials have to be traced, according to European legislation.

The European General Food Law, regulation 178/2002, is generally concerned with food safety and therefore only refers to packaging materials within the category of materials in contact with food (apart from a reference to the fact that packaging must not mislead consumers).

This regulation makes reference to the need for provisions which cover materials in contact with food, and sets up a scientific committee on the subject, but does NOT require the traceability of materials in contact with food. This is therefore not obligatory from January 2005.

However, a new regulation concerning materials in contact with food (1935/2004) was published a few weeks ago. This regulation makes the traceability of all materials which come into contact with food obligatory through all stages of manufacture, processing and distribution from 27 October 2006. There may be other aspects of this regulation of interest to those producing or using food packaging materials.

Regards

[Simon]

However, a new regulation concerning materials in contact with food (1935/2004) was published a few weeks ago.  This regulation makes the traceability of all materials which come into contact with food obligatory through all stages of manufacture, processing and distribution from 27 October 2006.  There may be other aspects of this regulation of interest to those producing or using food packaging materials.

<{POST_SNAPBACK}>

Hello idtrack, welcome to the forums. :)

There has been some discussion on 1935/2004 here:
http://www.saferpak....p?showtopic=811

From my experience I can tell you 178/2002 has encouraged food manufacturers to show a lot more interest in their packaging manufacturers traceability systems. Partly through the process of analysing their own traceability systems and maybe some of them think direct contact packaging is (or should) be included under 178/2002. Either way it'll help packaging businesses be prepared for 27 October 2006 when 1935/2004 comes into force.

Thanks for your input.

Regards,
Simon

[Charles Chew]

However, a new regulation concerning materials in contact with food (1935/2004) was published a few weeks ago. 

This regulation makes the traceability of all materials which come into contact with food obligatory through all stages of manufacture, processing and distribution from 27 October 2006.

Hi Robert,

In essence, the interpretation of "food" should cover the primary packaging as does in a hazard analysis. It is the assurance of the appropriateness and hygienic condition of the packaging that keeps the integrity of the product to remain safe for public consumption whether in terms of sealing integrity, impact barrier etc or potential critical hazards that may prevail in the material of the packaging itself.

Therefore, in the case of 1935/2004 - it does make a whole lot of sense.

Cheers
Charles Chew

[Charles Chew]

However, a new regulation concerning materials in contact with food (1935/2004) was published a few weeks ago. 

This regulation makes the traceability of all materials which come into contact with food obligatory through all stages of manufacture, processing and distribution from 27 October 2006.

Hi Robert,

In essence, the interpretation of "food" should cover the primary packaging as does in a hazard analysis. It is the assurance of the appropriateness and hygienic condition of the packaging that keeps the integrity of the product to remain safe for public consumption whether in terms of sealing integrity, impact barrier etc or potential critical hazards that may prevail in the material of the packaging itself.

Therefore, in the case of 1935/2004 - it does make a whole lot of sense.

Cheers
Charles Chew

<{POST_SNAPBACK}>

[Franco]

I am picking up on an old discussion

Me too folks. Recently issued EU guidelines on 178/2002.

The 178 comes into force on 1 st January 2005. Is this document the result of EU JIT quality policy ?

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