BRC metal can packaging compliance requirements
Hope everyone is staying safe!
Can any one please clarify whether followings are covered by BRC packaging standard?
1. EU regulatory compliance for food grade internal coating EU 10/2011 - plastic material and articles intended to come into contact with food.
2. FDA regulatory compliance for internal coating FDA 21 CFR 175.300
3. Heavy metal compliance - European directive 94/62/EC
This is for metal can manufacturer for food packaging.
Thank you in advance. Stay Safe.
What do you mean "covered by" the BRC standard?
It is designed to be able to be applied by lots of different sites in every country/region, so the general requirement is that products must comply with the markets into which they're sold.
It would therefore potentially be possible for e.g. a US manufacturer who doesn't supply into Europe to make packaging that doesn't comply with 10/2011, whilst still being fully compliant with the standard.
Edited to add: Regulation (EU) 10/2011 is primarily about plastic food-contact materials, so unless there is some sort of plastic layer involved inside the can, it may be the more general Regulation (EC) 1935/2004 that you'd need to consider.
Throughout the standard it states you are making a safe and legal product. It is up to you as the manufacturer to understand what is "legal" for the markets you are supplying.
Echoing what pHruit says, there is no way they could spell out each specific regional regulation in the standard based on the use by varying packaging industries.
Also, in my experience, some regulations are updated far more frequently than the standard is so it would be impractical to call out specific regulations.
I concur with the previous posts, but if you are looking at can making, in addition to the European framework legislation 1935/2004 you need to look at EU1815/2005 for epoxy coatings and EU2018/213 related to BPA levels in food contact materials.
Cans are commonly coated with epoxy based materials and many of these have elements of BPA in their formulations.
With respect to 94/62EC, this is primarily an environmental waste disposal regulation and whilst not specifically within the scope of the Standard, may come up under waste control and potentially be relevant in an additional Voluntary Module
Thank you all. I think my doubt is now clear.
Stay Safe!
BRC certification does not guarantee that you are complying with European regulations. You cannot tell a customer that "we are BRC certified so this automatically means we comply with all European food contact regulations".
As mentioned above, if you are BRC certified, you are required to determine that you meet the regulations in all the countries where you state compliance.