ubpart C--Recalls (Including Product Corrections)--Guidance on Policy, Procedures, and Industry Responsibilities
Sec. 7.59 General industry guidance.
A recall can be disruptive of a firm's operation and business, but there are several steps a prudent firm can take in advance to minimize this disruptive effect. Notwithstanding similar specific requirements for certain products in other parts of this chapter, the following is provided by the Food and Drug Administration as guidance for a firm's consideration:
(a) Prepare and maintain a current written contingency plan for use in initiating and effecting a recall in accordance with 7.40 through 7.49, 7.53, and 7.55.
(b) Use sufficient coding of regulated products to make possible positive lot identification and to facilitate effective recall of all violative lots.
© Maintain such product distribution records as are necessary to facilitate location of products that are being recalled. Such records should be maintained for a period of time that exceeds the shelf life and expected use of the product and is at least the length of time specified in other applicable regulations concerning records retention.
I would think that packaging would fall under the item in red. You probably wont find legislation that requires you (GFSI program do however require it) but you'd be foolish not to
Is your company seriously saying "WHY??"........so if you don't track lots of containers, and your supplier tells you they labelled non food grade as food grade...how are you going to recall?? OR are you prepared to just recall everything you've made??