8 replies to this topic

[Franco]

Will be coming into force on 27/10/2006, yet it seems the first step to food packaging traceability. See art. 17
Regulation 1935/2004.
Rgds. Franco

[Simon]

Thank you Franco. To follow on a little:

The Framework Regulation on materials and articles in contact with food (Regulation (EC) No. 1935/2004) was published in the EU Official Journal on 13 November 2004.

This Framework Regulation is going to replace EU Directives 89/109/EEC and 80/590/EEC. And in contrast to an EU Directive, a Regulation is directly binding in EU member states.

With specific regard to the traceability of materials and articles intended to come into contact with food. The traceability should be ensured at all stages in order to facilitate control, the recall of defective products, consumer information and the attribution of responsibility (Article 17). Business operators should at least be able to identify the businesses from which, and to which, the materials and articles are supplied.

Please note that the provisions for Article 17 (traceability) will come into effect on 27 October 2006.

It is likely that there will be some confusion in the market on traceability requirements because according to EU Regulation 178/2002 of 28 January 2002 laying down the general principles and requirements of food law, establishing the European Food Safety Authority and laying down procedures in matter of food safety, traceability requirements for the food industry come into effect as of 1 January 2005.

But - from a strictly legislative point of view - the traceability requirements in EU Regulation 178/2002 do not refer to packaging producers but to the food industry only. For packaging producers the new Framework Regulation No. 1935/2004 on materials and articles intended to come into contact with food is relevant as far as traceability requirements are concerned. And in this Regulation traceability requirements will come into effect as of 27 October 2006.

You can imagine that it will be difficult to explain to important customers that traceability requirements for packaging producers are effective only as of 27 October 2006, while the food industry has to ensure traceability already as of 1 January 2005. This is indeed somewhat inconsistent from a practical point of view.

But from a strict legislative point of view it is absolutely correct because EU Regulation 178/2002 refers to the food industry, and the Framework Regulation No. 1935/2004 refers to packaging.

Regards,
Simon

[Franco]

You can imagine that it will be difficult to explain to important customers that traceability requirements for packaging producers are effective only as of 27 October 2006, while the food industry has to ensure traceability already as of 1 January 2005. This is indeed somewhat inconsistent from a practical point of view.

Yeah, right mate. The legal distinction is that food is intended to be eaten by human beings or animals used for food production (feed is in the scope of 178 too), while packaging is is solely intended to be thrown away as waste, hence the two Reg.s and the two dates.
What if food is suspected to be contaminated by interactions with packaging ?
No mandatory traceability is required for packaging.
This is why in our company we track and trace packaging materials as well as food.

[Simon]

What if food is suspected to be contaminated by interactions with packaging ? No mandatory traceability is required for packaging. This is why in our company we track and trace packaging materials as well as food.

<{POST_SNAPBACK}>

No it's not currently mandatory, but I would say most (if not all) in the UK/EU have this covered already. I might be wrong.

Simon

[Charles Chew]

I agree with Franco that regardless of the lack of mandatory requirements, it is in the interest of responsible food processors to understand the "one-step backward" principle of traceability in order to fully complete the entire tracing cycle of a specific hazard risk assesment.

Although primary packaging are not "consumed", it is a direct food contact material/surface anyway which makes it significantly enough to warrant being a food safety suspect potential when the situation warrants it.

Charles Chew

[Franco]

Will be coming into force on 27/10/2006

Is there any guideline, code of practice and stuff like that ?
I haven't find any.

[Franco]

General guide to packaging traceability

General guide for food contact paper and board traceability from FEFCO


FSA packaging traceability guidelines

[Franco]

Traceability applied to metal packaging for food and drinks

[Simon]

Thanks Franco I've saved it to read later.

Have a nice day.

Simon