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.