10 replies to this topic

[Alutka_120]

I have one question,

We are food producers.

Our packaging supplier/ manufacturer sent us declarations of conformity and and a statement that they will check global and specific migration on what fluids and under what condidtions and that it is ok.

But they do not send reports to third parties ( only show raport during inspection)

Whether sending migration reports in not a requirement?

 

[Dorothy87]

Hi, 

 

This shall be verified by your packaging risk assessment. I believe is a primary packaging ?

 

I would ask for COA (Certificate of analysis) if this is a primary packaging

 

 

[Alutka_120]

Yes
This is direct packaging.
The supplier has described the results and under what conditions it will perform the migrations in the declaration.
And separately wrote a statement that he is performing.
However, it does not send reports to third parties.
I would like to emphasize that this supplier also has the BRC standard.
Are reports a requirement or are the documents he sent enough?

[SQFconsultant]

As an Auditor I would be asking for proof of non-migration, regardless of way presented as a stand alone or as a part of another document. As long as you have it and it looks professionally done, etc there would be no issue.

[Dorothy87]

again, I would check my risk assessment.

 

1 (low risk)  if the migration or food grade certificate is provided for allergens content and potential contamination, FB risks, micro contamination, chemical & radiological contamination, verity or species cross-contamination, and whether the packaging might affect final product quality. 

 

2 if supplier only offers their own interpretation of the results in a form of a conformity statement

 

3 - lack of migration / food grade certificate 

 

Double check if the material was recycled..  for more ; 

migration-guideline-consultation-draft-august-2015.pdf (pac.gr)

 

Alternatively you can always say, that without COA you wont be able to approve them. 

 

[Alutka_120]

​Thank you for your answer.

However, two suppliers have already replied to me that they do not provide reports to third parties only during inspections or

only pass on test reports to authorised authorities.

where the declaration describes in detail how the research was carried out

And I emphasize that these suppliers/manufacturers have branches in several countries and have certificates recognized by GFSi.

 

 

so I don't know whether this is a requirement of the migration report or whether the declaration itself and the test results in the declarations are enough.

 

 

 

[MOHAMMED ZAMEERUDDIN]

Migration certificate is required.

[Scotty_SQF]

How is your approval of these suppliers set up?  Do you have it that it is required to have these migration certificates?  If so, then you have to follow what you wrote or update your program.  I would believe a simple declaration from the packaging companies on a signed letterhead would be sufficient as they are still then holding the responsibility and you would then have their declaration to cover you and fall back on them if there was an issue.  

[HaloQA]

Hi,

We are a packaging company that basically erects trays for food contact with materials purchased from other packaging manufacturing companies (they and us are BRCGS certified). They provide us statements confirming they passed migration tests according to certain regulation or standard and we confirm the same to our customers (we also carry tests when we modify the materials). As far as I have been working on this matter (7 years already), we never had problems with it and auditors always accepted this way. I cannot see the relevance of having to send the specific report or requesting the specific report if that company already confirms it complies with relevant applicable rules, unless you doubt of the veracity of their declaration, in which case I would suggest to not work with that specific supplier. 

[Alutka_120]

Thank you for your answer.

This is helpful for me

[weaam]

Hello, 

I work in a BRCGS certified food packaging production company. We perform overall migration tests in third party laboratories frequently and upon request from our clients. We also share the report of the results as received from the lab in addition to food contact declaration that we prepare internally. The BRCGS auditor usually asks us about at least one overall migration test done in an accredited lab during the year. So I think that your supplier should have the test report from the third party lab.