Declaration of Compliance
Hi All,
Does anyone out there have a declaration of compliance for printed cardboard cartons?
I would be very grateful for any help.
K
If you are looking for a general FDA compliance letter, one is attached. This example comes from a reputable carton/cardboard supplier in the USA.
Hope this helps,
jpainter
Hi Kristina,
it all depends on what you are compliant with.
We manufacture printed cartons from virgin board and In line with BRC for packaging clause 3.4.3 we have a declaration . Check out the clause and then check out your raw materials to see what you are compliant with.
Generally the customer is wanting you to declare compliance with EU Regulation;- 1935/2004 materials and articles intended to come into contact with food. There are other requirements for plastic packaging etc. The customer may also like to see EC 2023/2006 (GMP).
You would need to ask your suppliers to give you that assurance first. The board suppliers, the ink, varnish suppliers and if you make cartons perhaps the glue suppliers. See what their declarations say and chop the bits you need from there to make your own. AS LONG as you do comply of course.
There is a BRC Position Statement about Declarations for Paper which is quite general, but it will form part of an audit.
More helpfully, the new CEPI Guidelines have a whole section on preparing Declarations.
As said previously, you will need to get data from your suppliers in order to construct your own Declaration.
Attached Files
Who should sign a declaration of compliance, MD or Quality Manager?
K
Depends on your company setup - if the QM has sufficient authority then I wouldn't see any problem with them signing.
Hi all my name is mike and I have been asked for a DoC for our products. We are a paper and board business and are non food contact so am I right is saying that we don't need to provide a DoC. We are BRC basic certified and have not been asked for this before.
Any assistance would be grateful
Even the Basic Hygiene Level of BRC Packaging Issue 5 has the requirement for a D of C, (Clause 3.4.3 under specifications) so in truth, you should have been asked for it during your audit.
From a legislative point of view it is a bit less clear, as presumably your products are not food contact. The D of C that most people refer to comes from various EU Food Contact law, especially the plastics 10/2011.
What I am finding at the moment is that most UK customers seem to have a list of requirements which they send to their suppliers regardless of whether it is relevant to the material being supplied.
Looking for clarification on this as well. We do not currently supply products to the EU. Would that negate the need to meet this requirement? We have a standard Letter of Guarantee we supply our customers in the US, but reading the interpretation guideline for Issue 6 of the Packaging Standard it sounds to me like this is only required if you supply the EU since it is an EU regulation they are asking about compliance with.
Any help would be greatly appreciated.
Looking for clarification on this as well. We do not currently supply products to the EU. Would that negate the need to meet this requirement? We have a standard Letter of Guarantee we supply our customers in the US, but reading the interpretation guideline for Issue 6 of the Packaging Standard it sounds to me like this is only required if you supply the EU since it is an EU regulation they are asking about compliance with.
Any help would be greatly appreciated.
The IG focuses on the EU as the requirements for plastic food-contact materials are very specific here. Nonetheless for a document that purports to be a "global" standard, it is unusually narrow in the guidance it gives...
It's worth noting that (at least theoretically) auditors can/should only audit against the standard, and 3.4.3 itself doesn't require the EU declaration - only that you have "confirmation that the packaging meets relevant legal requirements". If you've documented that you're only supplying to the US, as would presumably be defined already in e.g. your response to 2.2.2, then your obligation would only be to confirm US suitability.