Clause 7.3.3.1 - FDA Approved Material of Packaging
Dear all,
To comply with clause 7.3.3.1 of ISO 22000, do we need to specify composition of raw material, such as resin? Because sometimes supplier don't want to specifically define the composition since it is confidential. They only mention that the additive used in resin is comply to FDA and suitable for used in food contact.
Is it adequate if supplier only mention that their product is comply to FDA, or is there any evidence needed to ensure that the material comply to packaging regulation
Thank you for your help
I work for a company that makes food packaging material. What we do for our customers is send a "FDA Letter of Guarantee" which states that we comply with all of the FDA guidelines. Sometimes states, countries, or different industries will have specific requirements (usually due to environmental reasons) and our customers will ask us about that. The best way to do deal with that is to send us your request, as an example we had a request about if our PET was "reportable" to the Canadian government, so they sent us the links and all of that. If you give us enough time, we can go through our supply chain and make an additional "Letter of Guarantee" specific to whichever substance you need to know about. So, if you are being asked about a specific resin, I would send that question directly to your suppliers.
Your supplier should include more detail in his claim.
Please refer to the Regulatory Data Sheet we receive from our suppliers. This is the quality of information you need.
Tamale
Attached Files
Hi Tamale, thanks for the information. Have you really gone through the details if the clauses mentioned is comply with standards?
No Carine, for us its enough that the supplier claims to be honest. After that its his responsibility to answer to the regulators such as the FDA. Also, we are molders and printers, we do not have the expertise or the resources to do in depth analysis of his claims.
Tamale
No Carine, for us its enough that the supplier claims to be honest. After that its his responsibility to answer to the regulators such as the FDA. Also, we are molders and printers, we do not have the expertise or the resources to do in depth analysis of his claims.
Tamale
Hi tamale,
But are you not responsible for yr own output ? And also the last known Production step ?
I fear that ignorance is no excuse for the FDA unless they have copied the UK Regulatory credo of due diligence ?.
Sorry Carine and Charles,
I should have written CFIA and not FDA, The Canadian Food Inspection Agency changed its policies in the last years and the change reflects what I have written. They used to demand that a letter of no objection (LNO) be secured from them but this was dropped I believe in 2013. An LNO involved a safety analysis by the agency of the content of your product according to its target use. A letter of «approval» was then issued. They actually still issue them but its on a voluntary basis.
Tamale