Post Consumer Waste Traceability

Hello All,

We are looking at the possibility of using Post Consumer Waste within our company which produces polythene film, this is primarily to comply with the plastics tax. My concern is if we buy in post consumer waste is how we deal with the traceability aspect, this is particularly concerning when being auditing by the BRCGS.

Thanks in advance.

Your post reads as though you'll be buying PCW plastic from a commercial supplier, in which case your traceability obligation is only to be able to identify them as your source.

For your supplier approval, you'd need to ensure the requirements of 3.7.5 are covered - i.e. if the supplier isn't certified or physically audited in accordance with the first two options of 3.7.2 then you'd need to get them to do a traceability exercise, but that traceability is their responsibility rather than yours.

One other thing is we are primarily a manufacturer of food contact materials, would this have any bearing on this?

Tangentially to the traceability point, I believe.
It would likely increase your requirements in terms of approving the material and supplier, and potentially in terms of your own testing (e.g. with respect to Regulation (EU) 10/2011), but the same general traceability requirement will apply.

I haven't heard of any recyclers being GFSI certified so you will need to undertake a traceability exercise with them when life gets back to normal, either remotely or as part of an on site audit organised by yourselves.

Make sure that the supplier is registered under EU282/2008 and keep a copy of the EFSA judgement on file as part of your approval evidence. If they are registered, their traceability systems will be defined and your exercise should be fairly straightforward