Do we need a specification sheet for non-direct contact boxes?

Hi, Caroline;

No, they do not have to be GFSI but they still are required to meet regulatory guidance and should be able to demonstrate this is some manner via the Approved Supplier Program (2.3.4)

I have always maintained specifications for corrugated master cartons (dimensions, additives, ECT, preprint/color, etc.), However no auditor has ever looked for this beyond direct (primary) packaging but it is a good practice as a continuity measure. Here is the code from 9th ed. without the guidance part:

 

2.3.2.6 Verification of packaging shall include a certification of all packaging that comes

into direct contact with food meets either regulatory acceptance or approval criteria.

Documentation shall either be in the form of a declaration of continued guarantee

of compliance, a certificate of conformance, or a certificate from the applicable

regulatory agency.

In the absence of a certificate of conformance, certificate of analysis, or letter of

guarantee, analyses to confirm the absence of potential chemical migration from the

packaging to the food contents shall be conducted and records maintained.