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Position Statement P616 - Functional Packaging


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nwells1024

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Posted 09 December 2020 - 06:38 PM

Hi there everyone, I was reading over one of the recently released position statements from BRCGS (P616 Functional Packaging Claims) and I was a bit frustrated at its vagueness. A colleague and I are on opposing sides of the argument of whether it applies to our organization so I was hoping to plug into this forum to gauge others' thoughts. My company produces oriented polypropylene films for (amongst other uses) direct food contact. We do not do any printing or laminating; we sell films to converters to make the actual packages. While we have films with certain barrier characteristics, we have never guaranteed anything such as 'increases shelf-life by 20%'. What are your thoughts on how far reaching this claim of 'functional packaging' goes? Does it apply to film makers or is it more for the ones assembling the package? Thanks in advance, and cheers! Nick



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Posted 09 December 2020 - 07:57 PM

It would apply to both the film maker and the ones that assemble.


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Posted 09 December 2020 - 07:58 PM

I'm not in the packaging sector, but my reading of the statement is that it could apply to a manufacturer of films, or other component parts of packaging, if those component parts claim/confer some sort of functional benefit.

It does seem to leave the onus with the business to decide if they are offering a material that falls into the scope of this, so if you aren't making any sort of specific functional claim. If you are saying to your customers that your barrier properties e.g. "reduce oxygen transmission by x%" then that is effectively a functional claim, and in the context of the clause the objective would be for you to provide evidence to your customers that your packaging achieves this effect. Even if you are not selling "finished" packaging, your client would still need reasonably be expected to want/need the evidence to be able to develop their subsequent packaging material.

I don't necessarily see it as being hugely onerous for this category of claim, as presumably the testing has been conducted already to verify for your own purposes that the intended barrier effects work as expected?



nwells1024

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Posted 09 December 2020 - 08:20 PM

My only concern is the comment about an outside lab. Why should I have to pay an outside lab perform oxygen transmission testing on my commercial films when I test this property in standard QC and report it on every COA? If it were for a claim that wasn't a measurable property (i.e. my 'increases shelf-life by 20%' example from above), then I could understand. If anyone would have an example of what they think BRC may be looking for, that would help alleviate my confusion I think.

 

Nick



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Posted 10 December 2020 - 04:32 AM

My only concern is the comment about an outside lab. Why should I have to pay an outside lab perform oxygen transmission testing on my commercial films when I test this property in standard QC and report it on every COA? 

 

Nick

No. You don't have to because it says "Where appropriate". A COA is fine (by common sense?). 

 

 

 

If it were for a claim that wasn't a measurable property (i.e. my 'increases shelf-life by 20%' example from above), then I could understand. If anyone would have an example of what they think BRC may be looking for, that would help alleviate my confusion I think.

From the latest audit my company has had, BRC probably (perhaps by the auditor's interpretation) requires more specific usages and purposes of packaging products, e.g. for dry powder foods, for pesticide, etc. So that I think a claim might need to be clearer as "increases shelf-life of coffee powder by 20%" and/or "increases shelf-life of typical mayonnaise by 15%", etc.

The problem is some packaging products in reality have many food and non-food applications. Example, a simple PE film can be used with plenty kinds of food. Detailing every claim could lead to a cumbersome workload.

IMPOV, another concern is how a new clause appearing for newly developed materials applies on conventional one? Before that, the conventional have been already proven to be okay for years, practically and commercially. Then is an exclusion from such new requirements possible and realised by auditors?



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Tony-C

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Posted 10 December 2020 - 05:59 AM

Hi Nick,

 

For me this is like for any claim, food or packaging, BRC will require proof of the claim/effect claimed.

 

So, from P616: Position Statement Additional requirement for functional packaging claims

In addition to the requirements of clause 3.4.3, the following supplementary requirement in italics shall apply and be included within all audits commencing 1st July 2021:

Where such claims are made for functional packaging produced for product safety assurance or improvements, the proof of effectiveness shall be documented on the statement of compliance.

 

My view is this would apply to your organisation if you or the converters are selling your packaging products with any such claims. If you are not then it does not apply but I would be stating on specifications that you are not making any functional claims unless specifically requested.

 

The interpretation is interesting, for example: Where such claims are made for functional packaging produced for product safety assurance or improvements, the proof of effectiveness shall be documented on the statement of compliance.

The information shall include as a minimum:

• the intended use of the packaging materials

• The functional effect(s) e.g. extends shelf life by 20%

• The tests conducted and results

• The name of the laboratory and accreditation details

Where appropriate to the specified functional effect, the documented evidence shall include the following tests

• Chemical, sensory and migration

• Head space analysis

• Oxygen and water transmission rates

• Shelf life trials

• Microbial leakage

• RFID performance

 

I don’t see how you can show your packaging, in the form you sell it, extends shelf life etc. without collaboration with the converters and food manufacturers.

 

Regarding Laboratory Analysis, your results would be acceptable if you meet the requirements of 7.3.4:

Where the company undertakes or subcontracts analyses which are critical to product safety or legality, the laboratory or subcontractors shall have gained recognised laboratory accreditation or operate in accordance with the requirements and principles of ISO 17025.

But for claims, supporting information is required 7.3.3:

Where claims are made about the products being handled, including the provenance, chain of custody or assured status of a product, supporting information shall be available from the supplier or independently to verify the claim.

I see this as an area where you could conduct your own analysis but also have independent analysis which could then be reduced based on risk and history/consistency of results.

 

Kind regards,

 

Tony



nwells1024

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Posted 15 December 2020 - 07:57 PM

Hi Tony,

 

Section 7 covers requirements for traded products, so these do not apply to products produced and sold by the certified site.



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Posted 16 December 2020 - 04:08 AM

Hi Tony,

 

Section 7 covers requirements for traded products, so these do not apply to products produced and sold by the certified site.

 

Thank you for pointing that out Nick, sorry, I quoted the wrong sections:

 

5.6 Product inspection, testing and measuring - 5.6.10

Where the company undertakes or subcontracts an analysis critical to product safety or legality, the laboratory or subcontractors shall have gained recognised laboratory accreditation or operate in accordance with the requirements and principles of ISO 17025 for the test undertaken (General requirements for the competence of testing and calibration laboratories).

 

3.8 Product authenticity, claims and chain of custody

Systems shall be in place to minimise the risk of purchasing fraudulent raw materials for packaging and to ensure that all product descriptions and claims are legal, accurate and verified.

 

Kind regards,

 

Tony


Edited by Tony-C, 16 December 2020 - 04:08 AM.





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