Are there Obligations for Food Packaging Companies to Carry out HACCP?

Hello all members taking part in this issue

Reading all your comments regarding packaging companies, moreover, food packaging companies, something come into my mind. Months ago, a health authority of my country ( Spain ) told me that there is no obligation for food packaging companies of developing and implemeting a HACCP system as such.

I would like to know where, in the european regulations or in your national regulatons, it is said that they must implement a HACCP system ?

On the other hand, recently I had a discussion regarding the packaging material intended to be used for food packaging. The point of discussion was, must the material intended for food packaging , but not only the materila for direct food contact, comply with the requeriments that apply for the material intended for direct food contact ?

What do you think or what you had done in your industry ?

Regulation ( CE )1935 / 2004 states: " material intended for direct and indirect food contact......".

Hoping to hear from you.

Sincerely

Esther

Months ago, a health authority of my country ( Spain ) told me that there is no obligation for food packaging companies of developing and implemeting a HACCP system as such.

I would like to know where, in the european regulations or in your national regulatons, it is said that they must implement a HACCP system ?

I don't believe there is in EU. BRC Food Packaging Standard is a customer requirement and has the requirement for hazard analysis (HACCP?).

On the other hand, recently I had a discussion regarding the packaging material intended to be used for food packaging. The point of discussion was, must the material intended for food packaging , but not only the materila for direct food contact, comply with the requeriments that apply for the material intended for direct food contact ?

What do you think or what you had done in your industry ?

If the packaging is non food contact then it does need to comply with food contact legislation. But probably the customer will want secondary food packaging to be produced under sanitary conditions. See BRC Packaging Standard Category A supplier for requirements.

Regulation ( CE )1935 / 2004 states: " material intended for direct and indirect food contact......".

Did you change the statement Esther or have I missed something?

Hello Simon

See regulation 1935/2004, point (3), previous to article 1.

Sincerely
Esther

Hello Simon

See regulation 1935/2004, point (3), previous to article 1.

Sincerely
Esther

Hi Esther, of course you are correct. I had my blinkers on and was thinking only of packaging instead of materials and articles.

The new European Regulation (EC) number 1935/2004 replaces the existing controls on materials and articles in contact with food. The European regulation is now applicable throughout the EU and came into force on 3 December 2004...

...Provisions also apply to materials and articles that can reasonably be expected to come into contact with foods or to transfer their constituents to food (such as printing inks and adhesive labels).

Read the full overview on Food Standards agency website - click

And in terms of indirect articles mentioned such as printing inks they should not be in contact with food at all and as an extension of 1935/2004 new legislation is coming: Commission Regulation (EC) No. 2023/2006, GMP for Food Contact Materials & Articles

Regards,
Simon

Dear Simon,

Yr "click" link didn't work for me, > "failed to load" ?

Was any conclusion reached on Esther's original query?. I have some interest in this since a while ago I audited a packaging supplier who produced both plastic / cardboard containers for direct food contact and outer cartons within which these sub-units were placed.

His (always a male!) logic was that since the outer material was non-direct contact it permitted the use of (a) different "criteria" regarding the actual composition of the packaging material and (b) an establishment which had less severe controls on certain sanitation items such as dust controls, footbaths etc as compared to the clearly direct contact production. I was unhappy over this logic but found it difficult to resolve the risk (a), and also (b) the latter both conceptually and practically (for example that inner packaging might break and thereby the contents contact the outer carton with consequence XX).

Does this 2004 reg. fix the situation like above in that both cases are now equalised. ? (I noted that Esther's query is described as a "Principle" which also includes the word "intended" - ??)

Rgds / Charles.C

Yr "click" link didn't work for me, > "failed to load" ?

Strange that, I think it could have been a rogue space. Fixed now. Thanks Charles.

Was any conclusion reached on Esther's original query?. I have some interest in this since a while ago I audited a packaging supplier who produced both plastic / cardboard containers for direct food contact and outer cartons within which these sub-units were placed.

His (always a male!) logic was that since the outer material was non-direct contact it permitted the use of (a) different "criteria" regarding the actual composition of the packaging material and (b) an establishment which had less severe controls on certain sanitation items such as dust controls, footbaths etc as compared to the clearly direct contact production. I was unhappy over this logic but found it difficult to resolve the risk (a), and also (b) the latter both conceptually and practically (for example that inner packaging might break and thereby the contents contact the outer carton with consequence XX).

Does this 2004 reg. fix the situation like above in that both cases are now equalised. ? (I noted that Esther's query is described as a "Principle" which also includes the word "intended" - ??)

I agree with your auditee that non food contact material can be different composition from food contact material and would not have to meet migration limits, heavy metals limits etc. Although not free from sanitation criteria you would expect slightly less stringent requirements. This difference is reflected in the BRC Packaging Standard by two levels of requirements; one for food contact and one for non-food contact packaging.

I don't believe 1935/2004 equalises the above. The legislation cover materials and articles in contact with food, but the "indirect" caveat still confuses me and I would like to explore further.

Charles your idea that primary packaging could break causing the secondary packaging to come into direct contact with food and so the food contact rules should apply - I'm not sure. Again I'd like to hear arguments for and against.

Regards,
Simon

Dear Simon,

From yr click link -

The Agency is responsible for ensuring the public is adequately protected against chemicals that might transfer into your food from these materials, causing you harm or affecting the quality of your food.

but then nothing.

Clearly (eventually) "might" > risk assessment but does such exist ? I remember this coming up before with respect to compilations of migration data for direct contact situations but that is a different question.

Seems to me there could/should at least be a "minimum" requirement for non-direct but which could "inadvertently" become direct as per outer cartons in my example (maybe this is considered in BRC/pckg ??.)

I can see there are similarities to sanitation assessment of items like potential air-condition condensation dripping onto areas involving/not involving direct food contact. (This topic can become like ear-rings IMEX.)

@ BRC packaging / direct-indirect considerations

Interesting, any chance of a broad example regarding sanitation requirement differences ?

Rgds / Charles.C

added - if nothing else, I think these comments suggest that Esther's Question was a good one

@ BRC packaging / direct-indirect considerations

Interesting, any chance of a broad example regarding sanitation requirement differences ?

I'll dig out the standard and see what the main differences are.

added - if nothing else, I think these comments suggest that Esther's Question was a good one

Agreed.

Regards,
Simon