Outer Case Labels and the Label/Packaging Register

We are in the midst of trying to perfect our label/packaging register and we've audited all of our labels and packaging, with the exception of our outer case labels.  I feel strongly that these labels need to be verified and approved, but I'm getting push back about whether or not it is required per the SQF code to include these labels in the register. According to section 2.3.2.7 A register of raw and packaging material specifications and labels shall be maintained and kept current.

One caveat to this is that we print all of our own outer case labels so it would seem that in order to implement more controls with regards to these labels we would want them all "Approved" and documented within our already existing database and hold them to the same standards as we do our other packaging and labels.

If anyone could supply me with some additional support regarding this I'd greatly appreciate it.  I may be incorrect and more than happy to consider the alternative if someone can give me compelling reason why my reasoning is not accurate.  Either way, just looking for some feedback on this topic.

Thank you greatly!

I would agree with you, especially if the label contains critical information (i.e., ingredients, lot numbers, descriptions, etc.). We control our labels internally and require an engineering change order to modify the labels. Is there an approval process within your company to approve label art and content? I'm under the, better to have it and not need it, than need it and don't have it mindset.