Clause 18.104.22.168 states:
The company shall undertake a documented risk assessment of each raw material or group of raw materials including packaging to identify potential risks to product safety, legality and quality. This shall take into account the potential for:
•substitution or fraud (see clause 5.4.2).
Consideration shall also be given to the significance of a raw material to the quality of the final product.
The risk assessment shall form the basis for the raw material acceptance and testing procedure and for the processes adopted for supplier approval and monitoring. The risk assessments shall be reviewed at least annually.
This is important with respect to close contact packaging.
Maybe this will make the assessment a bit clearer.
I am not suggesting that this is the only/correct way of pursuing a vulnerability assessment , this is the way I chose to do it and it passed an audit this year.