Hi All,
We package our product into small tubs that are heat sealed with film. After cooling, we add a snap on lid. The lids are not technically food contact because of the film, however, consumers will theoretically remove the film and use the lid as a food contact closure. We obviously don't have any control over lid contamination at the end user but do we have an obligation to treat the lids as primary packaging or do we treat them as secondary because that's how the product is sold? All input is appreciated!