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Non Food Contact Packaging and Food grade materials


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NHer

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Posted 03 April 2021 - 11:00 AM

Hello all, I'm fairly new to BRC and hence would greatly appreciate the advise of the experts here in the forum. Can someone please let me know in terms of industry standards and good practices regarding Non Food contact packaging, do we need to use Food grade materials(i.e Low Migration inks/coatings and Food grade Paper/Board) for the packaging? That is to say if the prepacked food is primarily packed(by customer) with metal and there's no contact on the secondary food packaging we supplied, is it safe to say the materials for the secondary packaging doesn't need to be food grade materials? Does this still apply if the primary packaging(again done by the customer) is plastic or material used for microwavable food? I would appreciate any Feedback. Many Thanks



Ryan M.

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Posted 03 April 2021 - 01:21 PM

I don't know BRC standard, but I would think it is dependent on the material of your primary packaging (food contact).  Sure, anything overtime could possibly pose a risk to the food, but generally within the shelf-life secondary packaging poses little to no risk.  I haven't seen a requirement in SQF where secondary / tertiary packaging materials require food grade status.



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beautiophile

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Posted 05 April 2021 - 01:25 AM

Hello all, I'm fairly new to BRC and hence would greatly appreciate the advise of the experts here in the forum. Can someone please let me know in terms of industry standards and good practices regarding Non Food contact packaging, do we need to use Food grade materials(i.e Low Migration inks/coatings and Food grade Paper/Board) for the packaging? That is to say if the prepacked food is primarily packed(by customer) with metal and there's no contact on the secondary food packaging we supplied, is it safe to say the materials for the secondary packaging doesn't need to be food grade materials? Does this still apply if the primary packaging(again done by the customer) is plastic or material used for microwavable food? I would appreciate any Feedback. Many Thanks

I see this misconception a lot. A job of a packaging producer is to make food grade materials, not necessarily to acquire all food grade materials. For example, does a process of blowing glass bottles need food-grade certified silicate sand?


Edited by beautiophile, 05 April 2021 - 01:35 AM.


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Charles.C

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Posted 05 April 2021 - 08:29 AM

Hello all, I'm fairly new to BRC and hence would greatly appreciate the advise of the experts here in the forum. Can someone please let me know in terms of industry standards and good practices regarding Non Food contact packaging, do we need to use Food grade materials(i.e Low Migration inks/coatings and Food grade Paper/Board) for the packaging? That is to say if the prepacked food is primarily packed(by customer) with metal and there's no contact on the secondary food packaging we supplied, is it safe to say the materials for the secondary packaging doesn't need to be food grade materials? Does this still apply if the primary packaging(again done by the customer) is plastic or material used for microwavable food? I would appreciate any Feedback. Many Thanks

 

Hi NHer,

 

Not sure if you have studied the BRC Standard as yet ? Yr query involves things like risk assessment/hazard analysis/Regulatory factors.

 

I'm not a Packaging person but you may initially need to do a little "sideways" background reading, eg -

 

https://www.ifsqn.co...ng/#entry136137

 

https://www.packagin...-food-packaging

 

https://techni-k.co.uk/food-contact/

 

And maybe invest in BRC's "Interpretation Guidelines".


Kind Regards,

 

Charles.C


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NHer

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Posted 15 April 2021 - 04:48 PM

Hi NHer,

 

Not sure if you have studied the BRC Standard as yet ? Yr query involves things like risk assessment/hazard analysis/Regulatory factors.

 

I'm not a Packaging person but you may initially need to do a little "sideways" background reading, eg -

 

https://www.ifsqn.co...ng/#entry136137

 

https://www.packagin...-food-packaging

 

https://techni-k.co.uk/food-contact/

 

And maybe invest in BRC's "Interpretation Guidelines".

 

Thanks Charles for the links they are quite informative and I've also reviewed the interpretation guidlines.

 

I guess my query still remain, for arguments sake that primary packaging includes the prepackaging and outer packaging (i.e. cereal box - the plastic which holds the cereal and the box encasing it is considered as primary packaging, according to BRC). Another example is microwavable foods and their sleeves, where the food will be encased in microwavable plastic and the carton sleeve wrapped around it. As the cereal box and sleeve doesn't come in contact with the food is there a need to use Low migration ink also does the cartons themselves need to be food grade?

 

Logic dictates, which will translate into risk assessment and hazard analysis that since they are not in contact with food the risk is low and it is okay to use non food grad material. However as I've been informed recently that there are increased information that ink constituents migrates from the outer packaging to the product which would of course change how we risk assessed the non food contact packaging. Unfortunately they haven't gone back to me where they got this information and or if there are other information stating otherwise.

 

Hence I was hoping for guidance on where do they get their information to fully know that their risk assessment will be valid and their packaging product food safe. As well as examples from other packaging companies on how they dealt with non food contact packaging and food grade materials in their systems.

 

Kind Regards,

Naph



beautiophile

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Posted 16 April 2021 - 02:00 AM

I guess my query still remain, for arguments sake that primary packaging includes the prepackaging and outer packaging (i.e. cereal box - the plastic which holds the cereal and the box encasing it is considered as primary packaging, according to BRC). Another example is microwavable foods and their sleeves, where the food will be encased in microwavable plastic and the carton sleeve wrapped around it. As the cereal box and sleeve doesn't come in contact with the food is there a need to use Low migration ink also does the cartons themselves need to be food grade?

In my understanding, such inner plastic bag and outer box are still one "multilayer" packaging, and come together without glue or adhesive. Hence the requirement for migration test applies here.

A normal multilayer packaging is a paper box of milk. It actually consists of an inner plastic (usually PE) film directly contacting to milk, an intermediate aluminium foil acting as an oxygen & water barrier, and outer paperboard as framework & print substrate. All 3 layers are laminated by a certain adhesive. Your example is a loose type or "non-laminated".

 

Logic dictates, which will translate into risk assessment and hazard analysis that since they are not in contact with food the risk is low and it is okay to use non food grad material. However as I've been informed recently that there are increased information that ink constituents migrates from the outer packaging to the product which would of course change how we risk assessed the non food contact packaging. Unfortunately they haven't gone back to me where they got this information and or if there are other information stating otherwise.

 

Hence I was hoping for guidance on where do they get their information to fully know that their risk assessment will be valid and their packaging product food safe. As well as examples from other packaging companies on how they dealt with non food contact packaging and food grade materials in their systems.

Not many people dig deep into the terms. Firstly, non-food application packaging contains inedible stuff like electric devices; and of course doesn't need food-grade certificates. Then food-application packaging is divided into primary & secondary categories. Obviously, the primary must be safe for food. The secondary can be either food-grade or non-food grade according to hazard-risk assessments. Sometimes an assessment looks hard or confusing. Using food-grade secondary packaging sounds like a safe choice to avoid debates & arguments of risk level with auditors or customers, who are likely food/biology people and may have a moderate knowledge of materials science & chemistry. That is, in my opinion, necessarily overkill.

Also, a secondary packaging or the exterior surface of a primary one may be considered  "unintended food-contact" materials. For instance, people open a box, take out the biscuits inside, and use the box as a dish. This thing appears (and often gets overlooked) in a line of clause 2.2.6: • foreseeable misuse by the consumer.

Hope this helps a bit.

Edited by beautiophile, 16 April 2021 - 02:03 AM.


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