Clarification on ISO definition: Product Contact

Good day!

In reference to ISO/TS 22002-1:2009 Section 3.6, Product Contact is defined as "All surfaces that are in contact with the product or the primary packaging during normal operation".

I would like to be enlightened on the concerns below:

1. Does the term "primary packaging" on the definition refer to the inner part only of the packaging material (direct contact with the product) to be considered as a product contact material?

2. Or does it mean the primary packaging itself? Regardless if the product has indirect contact with the outer part of the primary packaging?

If our primary packaging is pouch and ink is being applied to the outer part of the pouch, does this mean that the ink is still considered as product contact material since it has direct contact with the primary packaging (pouch)?

Hoping for your immediate response and assistance on this matter.

Thank you!

If ink does not touch the product - it's not considered product contact material.

It means  the primary packaging as a whole

Are you printing before or after filling?

It means  the primary packaging as a whole

 

Are you printing before or after filling?

I should have also added, the issue in this scenario, is if you are using ink that could A) migrate through your packaging and B) is not approved for incidental food contact, you could, in theory, be contaminating your finished good with it

Hi Scampi,

Printing of the pouches are done after the filling process.