Packaging & Food Contact Substances
Hi there ~
I didn't see this topic come up, but it is on my mind a lot lately as we are considering switching packaging components very soon.
How often (and under what circumstances) do you request/require that packaging component suppliers register their food-contact components with FDA? For example, information on this is at http://www.fda.gov/F...S/ucm064161.htm.
For ordinary materials, such as glass, PET, polyethylene, etc., this wouldn't seem like it would be important.
However, any new process for making a food-contact substance, or a packaging component with exotic materials, seems like it would require it. It doesn't seem like a material safety data sheet/SDS would be enough.
What do you think?
Matthew
Packaging that is intended as a food contact material is not registered with the FDA. The FDA lists which materials may be used for food contact packaging and their restrictions. You suppliers should be stating what FDA compliance pertains to their materials. The FDA makes no provision for registering food contact materials unless you have a new material that went through the Food Contact Notification process. FDA compliance for food packaging is self-certifying: your supplier has to provide a letter certifying compliance.
My company makes food packaging and the only items we register are the trays that get used in the medical industry because these are technically Medical Devices. However, we still have a FDA letter of Guarantee that we use that states that we don't use any materials banned by the FDA, etc. I would request such a letter for all food packaging suppliers for you supplier approval and if they say they cannot because their materials are not GRAS by the FDA and they don't have any backup for that, they shouldn't be approved as suppliers. Technically, food packaging is an "additive" so you don't want anything to exotic/unknown that could be potentially harmful to the consumer.
Technically, food packaging is an "additive" so you don't want anything to exotic/unknown that could be potentially harmful to the consumer.
Hi herdy,
Packaging not my area but according to the book - Regulation of Food Packaging in Europe and the USA (2004). Knight,Creighton, there are various (US) exceptions to this statement. Does seem like a fiendishly complicated issue though.