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Expected Documentation for Food Contact Packaging Components Received

FDA Packaging BRCGS

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Posted 18 November 2021 - 06:39 PM

We are a food/beverage comanufacturer in the US and looking to become BRCGS certificated for our beverage division.

I am looking to gauge what is normal for food safety & shipping documentation for food contact packaging components for canned beverages (i.e. aluminum cans and can ends).

We have found that some prospective customers are sourcing packaging materials that may be shuffled around (ex. from Manufacturer to Distributor/warehouse) where the manufacturer pallet tag is removed and may not have a pallet tag replaced when shipped forward. It's my understanding that the paperwork that would be sent may not have lot numbers listed, but rather just a generic description (ex. cans, can ends) and quantity sent.

If shipped from manufacturer, pallet tags may or may not be present and/or may not have full lot info. If pallet tags are present, the assumption would be they would have traceable info we could gather.

Another issue is lack of COCs or COAs and/or detailed packing slips with traceability information. This means that if a distributor or other warehouse sends a pallet unlabeled and no details other than cans/can ends on the BO, there is no way to know the brand of cans/ends being sent.

Brands and customers have suggested these and/or detailed packing slips with lot numbers are not requested by other comanufactuers or very infrequently. I find this strange given the FDA and BRC/food safety requirements to ensure traceability for food contact packaging.

The manufacturers we are dealing with are the major common can & end brands. We don’t experience these issues with other food contact packaging components within our other divisions (i.e. rigid or flexible packaging for dry products).

I am hoping to gather input from the community here regarding documentation you require for inbound shipments of packaging items that come in contact with food/beverage product.

What have you experienced? Have you found similar challenges? What are your documentation requirements? What process do you use to ensure traceability? (Require specific information from the supplier or create your own internal process that is independent of the supplier)?

It seems that some of the major beverage packaging brands struggle with documentation that is commonplace and routinely provided for ingredients.

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Posted 30 November 2021 - 03:20 PM

Hi Jon19,


For documentation for food contact packaging, most common is a letter of continuing guarantee, FDA letter, food grade letter confirming the packaging is intended for food-contact use, specification sheet, composition statement, etc. Also, I suggest you check the SQF Guidance. Even though you are not getting SQF certified, SQF code is very good at explaining requirements and industry standards. 


A good/ reliable supplier would also have tests and analysis to confirm the absence of potential chemical migration form the packaging to the food. 


In regards to traceability, will the vendor at least provide you with a BOL and packing list? You can tag the packaging upon receipt with your own internal labeling so that you can keep track of the vendor, warehouse where it came from, etc. In that way, you would be able to trace one step back, and one step forward once it s used in production. Good traceability is imperative to a successful recall system and a proper compliance of food safety scheme. 


I hope this helps and let me know if I can assist in any other way.


Good luck!

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