Packaging Suppliers Approvals

Hello all,

We are performing our annual suppliers documents review and I have few questions:

1) As we are supplying finished product to Costco, all our suppliers (including packaging materials for the finished product) for Costco products must be 3rd party HACCP certified.

The majority of our packaging materials suppliers provided us with a certificate that states: "The facility was inspected by a qualified AIB International  inspector under the requirements of the AIB International Consolidated Standards for Food Contact Packaging Manufacturing Facilities."

The certificate has only the issue date, but doesn't have an expiry date. I attached an example of the certificate.

 Can it be considered a HACCP certificate?

2) We requested a Chemical Migration testing analysis , but only few suppliers were able to provide it. Isn't it a regular request in Canada?

Thank you and Happy Holidays! 

Hi, what they sent is laughable.

It is not a substitute.

All of our packaging suppliers have submitted chemical migration letters and/or copies of lab testing information -- you may need to press your suppliers and tell em to get in line and get it done or else.

Hey Alterman, 

 In answer to question 1, if Costco is anything like other big players I've dealt with they will typically tell you what schemes they accept for "third party HACCP certification." Having dealt with SQF, AIB, and ASI schemes, it comes down to what your customer (in this case it sounds like Costco) accepts. If Costco lets you decide what is acceptable in that regard, I'd take a long hard look at that AIB standard.

We co-pack for a customer that sells product to Costco. We have a Costco addendum to our BRC audit.
It's been a long time since I have done an AIB audit, but unless they have changed their grading criteria, the supplier achieved a "Superior" grade with that 900.

That being said, I agree with Glenn in that they should provide you with a migration cert or at least a letter that states that their food contact packaging complies with X regulation regarding food contact packaging.

Surely they have done their due diligence to ensure that standard.

Marshall

The FDA does not require you to provide migration test data when stating food contact compliance per 21 CFR.

The FDA does not require you to provide migration test data when stating food contact compliance per 21 CFR.

Really ? Thks.

Hopefully the FDA follow this Forum !

The FDA does not require you to provide migration test data when stating food contact compliance per 21 CFR.

Correct.  Typically, packaging manufacturers will supply you with a letter that states the materials used meet the specific FDA part of the code.  See attached.

Ask for a copy of the full inspection (audit) report and keep it in their supplier file. The full report should have all of the information necessary for your 3rd party audits. As far as chemical migration analyses, if that is your requirement and your suppliers aren't providing it, how can you approve them as a supplier? We are a food contact packaging manufacturer and only one of our customers asked for migration testing but stopped soon after as we are SQF Food Safety and Quality certified. We do provide LOCG for all customers that request it.

Something to keep in mind is that AIB is NOT a certification. It is a GMP audit/inspection. This is why there isn't an expiry date, just the date the inspection was performed. This is commonly misunderstood but even the AIB website explains this. If you truly require a 3rd party certification for food safety this would not meet that need.

Thank you all for your comments.

Don't trust the FDA.