You folks seem to be able to pick up the challenging topics. BRCGS had long convoluted discussions on the topic, whether packaging includes materials used to convey food (paper plates, straws, plastic utensils...), and where the cutoff is (a paper QSR destined coffee cup is, but a ceramic eat in restaurant cup is not). In the end, since the standards cover both product safety and product efficacy, and all the standards follow similar formats, we found it could be argued either way (Packaging Standard or Consumer Products Standard) and taking a firm position would be a little arbitrary.
The challenge comes in minimizing the risk of expecting certifications to multiple standards to cover all production in a facility. Think of the two situations:
A) a facility extrudes plastic drinking straws and clamshell packaging for fresh fruit. Using the Packaging Standard covers both products under the single certification.
B) a facility extrudes plastic drinking straws and children's toys. Using the Consumer Products Standard covers both.
Arguably, if someone produces all three, one standard won't work to cover everything, but to provide the best flexibility, the position statement above was a compromise to best serve the industry.
Input on the topic is always welcome....