3 replies to this topic

[salesmch]

Hi all.  I have a question that I hope you would be so kind as to help us.  It regards pertains to migration and extractables testing for a food packing item that comes in direct contact with food.

 

if the item is custom-made for a particular customer, who is responsible for the migration and extractables testing?  The ultimate customer who uses the packaging item or the food packaging producer?  Letters of compliance are on file for all of the raw materials used but we were wondering about the responsibility for migration testing.

 

Thanks 

[beautiophile]

Hi salesmch,

The the food makers (customers) have ultimate responsibility to filled products including packaging materials. To control the migration and extractable, they usually require packaging providers to give them test results/CoA/DoC/etc. in order to be confident. IMEX, they tend not to equip apparatuses to do those tests.

For packaging producers (I also work in), they are responsible to customers and to the laws or authorities for products coming out their factories. "Certification of Analysis - CoA" and "Declaration of Compliance - DoC" (of migration and other tests) should be available. Before their customers receive the products, they have accountability in case of any lawsuit issues, but no longer after the delivery; only explanation to customers.

For my company, we have tests and make DoCs for local region and for Europe (e.g. EC 11/2011) where we ship some our products to.

Hope this help.

[Charles.C]

Hi all.  I have a question that I hope you would be so kind as to help us.  It regards pertains to migration and extractables testing for a food packing item that comes in direct contact with food.

 

if the item is custom-made for a particular customer, who is responsible for the migration and extractables testing?  The ultimate customer who uses the packaging item or the food packaging producer?  Letters of compliance are on file for all of the raw materials used but we were wondering about the responsibility for migration testing.

 

Thanks 

 

Typically In the event of a problem the first line of attack is logically/accessibly the name on the label. Possibly followed by a  "deep-dive".

 

That's why "GFSI-recognised" certified FS standard  suppliers are in demand.

 

No idea about USA but in UK the producer may have legal liabilities for customised items also.

[moskito]

Hello,

 

in the EU we have a clear legal responsibilty for the DoC. But, as Charles wrote, the first line of attack is always the FBO printed on the label (as with any raw material used). But in the EU only the groups of FCM mentioned in the regulation 1935/2004 having a special regulation like plastic. But there are other matrials w/o such special measure. In such cases we require a DoC-like certificate.

 

Rgds

moskito