Migrations test on primary packaging
hello everyone,
I have a question and I hope this is the right section of the forum :)
Regarding article 17 of Regulation EC 178/2002 and according to Regulation EU No 10/2011, as food operator, we should garantuee the compliance of finished product we pack in several and different packaging items.
Till today we ask our packaging supplier to provide us Migration analysis and Declaration of compliance, but are these documents sufficient to comply to legal requirements?
Should we define a risk assessed control plan to evaluate migration on packaging after they come in contact to foods, or not?
Thanks for your help :)
Till today we ask our packaging supplier to provide us Migration analysis and Declaration of compliance, but are these documents sufficient to comply to legal requirements?
They should be sufficient, as long as you're buying the right packaging for your product types.
e.g. for 10/2011 compliance, you'll need to make sure that the migration testing is using the relevant simulants - see Annex III of Regulation (EU) 10/2011.
The declaration and specification should also make reference to the product types you're using them for.
I am assuming you have a disclaimer on your DoC that states 'This Declaration of Compliance describes the status of the material used in the manufacture of your packaging products. The recipient of the packaging products is responsible for ensuring that the packaging products are tested by relevant analysis as to the suitability of the packaging products under actual conditions of use The recipient is responsible for verifying possible interactions of the packaging products with the foodstuffs (e.g. modification of odour, taste, consistency, migration etc.).'
I would say no. If the migration levels are within the required levels then the documentation you have is sufficient. Any further testing should be carried as trials by the customer.
I am assuming you have a disclaimer on your DoC that states 'This Declaration of Compliance describes the status of the material used in the manufacture of your packaging products. The recipient of the packaging products is responsible for ensuring that the packaging products are tested by relevant analysis as to the suitability of the packaging products under actual conditions of use The recipient is responsible for verifying possible interactions of the packaging products with the foodstuffs (e.g. modification of odour, taste, consistency, migration etc.).'
yes I have that declaration, and also my supplier had it.
This is the reason why I was investigating about this topic :)
Thanks for your answer!
Dear AL Angel,
as product manufactuerer you have to demonstrate that your product is not contaminated i.e. you have to make the final step.
Regulation 10/2011 is for "plastc" only. What's with other materials?
Regulation 1935/2004 https://eur-lex.euro...ELEX:32004R1935 especially Art 3 has to be fulfilled.
primary (FCM), secondary, tertiary packaging -> this is not more valid.
see "mineral oil" or MOSH/MOAH discussion -> molecules will not enter the product by direct migration but also by gas transfer from secondary packaging (recycled fiber box) through a plastic layer (primary packaging) into a product if no barrier is present.
conclusion: The DoC of your packagiing supplier is only a part of the whole piece you have to cover as FBO.
Rgds
moskito