Pseudo Secondary Packaging
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!
Primary packaging. If you treat them as secondary, you may risk unhappy customers as they might add molds to your product at home....just a thought
Hello,
You shall consider it as a primary packaging. First, because of the migration risk through the film. And second, because there will be a part of the shelf-life of the product at the consumer, where the foil is removed.
Kind regards,
Gerard Heerkens
I agree that it should be considered primary packaging. Consider all "reasonably foreseen alternative uses" of the material.
Rabbit hole. Some of our products are packed into bags and then into boxes. (Think a box of vanilla wafer cookies).
Is it conceivable that some consumers may empty out the product from the bag and store it in the box? Rather than just fold over the bag inside the box? Like most normal people do? :shades:
If so, there is literally no such thing as secondary packaging.
However, in the OP's example, I agree.....primary packaging.
Marshall
Hi,
I agree. The definition of primary, secondary or tertiary packaging is no longer applicable today if you are focussing on the food inside a pack. The food should not be contaminated by any unwanted substance. Migration (e.g. primary amines, photo initiaors or MOSH/MOAH from an "outer" box through a film into a food should be prevent as much as possible. Even the term food contact material for primary packaging works well.
Rgds
moskito
Secondary packaging unless there is a migration issue through the film.