BRC Declaration of Compliance

Good Day All

This is my first post on this forum. i am working for a Packaging Company based in South Africa which main focus of Packaging is Ziploc bags for both food and non food use. We are busy implementing BRC and I am the Quality Manager and I have been tasked in getting this going. We supply packaging to countries in New Guinea and Italy and we therefore need Declarations of compliance for these countries. Is there anyone who can assist me with an example of what the declaration needs to looks like and what it should contain?

Thanks in advance

I can't help you with the language aspects of it, but for food contact packaging in the EU the general reference for compliance is Regulation (EC) 1935/2004 relating to food contact materials. If the material includes plastic then we would also expect to see confirmation of compliance with Regulation (EU) 10/2011, including reference to the applicable overall migration limits (OMLs) and simulants for the packaging and the foods with which it is intended to be used.

Similarly we expect to see compliance with Regulation (EC) 2023/2006, relating to good manufacturing practice for food-contact materials.

As you're dealing with plastic (I think?) you may also consider including confirmation on specific migration limits (SMLs), potentially as a list of materials used that are subject to these.

Customers may also have specific requirements that they want/expect to see - for example this could be around the absence of aromatic amines, heavy metals (Directive 94/62/EC), phthalate, PVC, Bisphenol A, genetically modified organisms, allergens (Regulation (EU) 1169/2011), BSE/TSE, epoxy derivatives (BADGE, BFDGE, NOGE) etc

Thank you very much for the feedback

This is a D of C that I did for a Kenyan company. It essentially follows the requirements in Annex IV of the EU Food Contact Plastics Regulation EU10/2011. In the absence of any local country legislation, the EU or FDA tends to have requirements that can be used and certainly if you are selling to Italy you will need to comply with EU10/2011.

You can add additional points such as BPA, BADGE etc., but I tend to have these in separate documents.

Obviously before making a Declaration, you need to confirm that the statements are correct and I would start by asking your supplier for his Declaration. 

Thank you very much for the feedback