9 replies to this topic

[Joseph Guerrinha]

Hello!

 

I am the SQF Practitioner for my company audited under Edition 9: Manufacture of Food Packaging standard. We import polypropylene bags used to package agricultural products, and we hand feed the bags through printing presses which print our customer names/logos on the bags. We provide packaging to customers in the grass seed, peas, lentils, animal feed, etc. industry. All we handle is the packaging, there are no food products in our warehouses.

 

We recently completed an SQF audit and the auditor informed us we need PCQI Training completed for the SQF Practitioner and Substitute SQF Practitioner. This was the first time an auditor mentioned this training to us (we have completed 4 SQF audits) so it came as a surprise.

 

I've been doing some research on the PCQI training and whether we are required to have it completed. On the FDA website it states "In general, the rule applies to facilities that have to register under Section 415 of the Federal Food, Drug, and Cosmetic Act (FD&C Act)". 

Section 415 states "any facility engaged in manufacturing, processing, packing, or holding food for consumption in the United States be registered."

 

Since we don't have any food in our warehouses, and are just handling the packaging, it seems like we wouldn't need the training. I am looking for any clarification someone could provide on whether or not the training is necessary? Are there any other companies similar to mine that have completed the training or stated why they don't need the training?

 

Any clarification would be greatly appreciated, thank you!

[TimG]

Did he tell you what section of the SQF packaging code (you did packaging right?) requires you to be PCQI trained? If it says it in the SQF code, you need to do it to keep SQF and that has nothing to do with FDA's PCQI requirement.

[SQFconsultant]

SQF does not specify this as a requirement for packaging.

 

i do recommend that  you contact your CB especially if you were gigged for this

 

As to the requirements by the FDA, it speaks of the requirement to register your company - like a bio # etc.

Edited by SQFconsultant, 25 March 2026 - 08:01 PM.

[Joseph Guerrinha]

Did he tell you what section of the SQF packaging code (you did packaging right?) requires you to be PCQI trained? If it says it in the SQF code, you need to do it to keep SQF and that has nothing to do with FDA's PCQI requirement.

 

Thanks TimG! It was mentioned during 2.9 Training when talking about training needs of personnel to comply with regulatory requirements. We are registered with the FDA which prompted the auditor to bring up PCQI training.

[Joseph Guerrinha]

SQF does not specify this as a requirement for packaging.

 

i do recommend that  you contact your CB especially if you were gigged for this

 

As to the requirements by the FDA, it speaks of the requirement to register your company - like a bio # etc.

 

Thank you SQFconsultant! 

 

That's how I interpreted the requirements as well. We were not given any non-conformance, but the auditor mentioned it should be completed if they come back to audit us again. So I will be reaching out to our CB for sure!

[Lynx42]

We are storage and distribution and we were told by 2 of 4 auditors that they thought we needed it. I pushed back that we were exempt and they said they'd get back to me but hey never did.  Another auditor never mentioned it and the last said we didn't need it.  Even talking to our CB they said they'd get back to me but didn't.  We aren't pursuing it.

[Joseph Guerrinha]

We are storage and distribution and we were told by 2 of 4 auditors that they thought we needed it. I pushed back that we were exempt and they said they'd get back to me but hey never did.  Another auditor never mentioned it and the last said we didn't need it.  Even talking to our CB they said they'd get back to me but didn't.  We aren't pursuing it.

Hi Lynx42. Yeah this was the first time any auditor had mentioned it so Im thinking we wont be pursuing it either! CB's are always fun to "communicate" with Lol

[jfrey123]

If your SQF CB didn't actually gig you for it, then I'd ignore it.  You're spot on that a PCQI is required for any company who "...manufacture, process, pack, or hold food..." so anything else is them grasping at straws.  Now, if your packaging is edible, then it's a food and you'd need this, but likely not.

 

Further fighting material?  I'm gonna go out on a limb and say your company's packaging probably has a foreign material component to it.  Does that mean you also have to have an FSVP qualified individual for importing that ingredient of your packaging?  (the answer is no, because packaging isn't food)

 

Now this is my take after dealing with a ton of food contact manufacturers who have thrown various levels of nuance into how FDA does not closely regulate food contact packaging like they do the actual food inside.  Someday maybe worthy of a separate thread, but ultimately packaging is not food and not as closely regulated by the FDA as food is.

[Joseph Guerrinha]

If your SQF CB didn't actually gig you for it, then I'd ignore it.  You're spot on that a PCQI is required for any company who "...manufacture, process, pack, or hold food..." so anything else is them grasping at straws.  Now, if your packaging is edible, then it's a food and you'd need this, but likely not.

 

Further fighting material?  I'm gonna go out on a limb and say your company's packaging probably has a foreign material component to it.  Does that mean you also have to have an FSVP qualified individual for importing that ingredient of your packaging?  (the answer is no, because packaging isn't food)

 

Now this is my take after dealing with a ton of food contact manufacturers who have thrown various levels of nuance into how FDA does not closely regulate food contact packaging like they do the actual food inside.  Someday maybe worthy of a separate thread, but ultimately packaging is not food and not as closely regulated by the FDA as food is.

 

Hi jfrey123. Appreciate the peace of mind, thank you! 

[Hoosiersmoker]

Can I ask why you are an FDA registered company? We make food contact packaging but we're not an FDA registered facility because there is no food in any of our processes. I would abandon the registration or deregister and that should eliminate the issue.

Edited by Hoosiersmoker, 08 April 2026 - 07:08 PM.