ISSUE #04QUALITY CONTROL AND TRACEABILITY OF rPET PACKAGING PAGE 5
The premise for traceability is deep knowledge about your material.
L I S A S T R A U B
F O O D S A F E T Y C O N S U LTA N T V I S C O T E C
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QUALITY CONTROL AND TRACEABILITY OF rPET
PACKAGING
A pragmatic interpretation of EC 2023/2006, Good Manufacturing Practice.
you can frankly say yes, great!
You have most probably fulfilled all
requirements in terms of traceability.
If you combine this traceability with a strict
internal quality control you will make your
customers and future auditors very happy.
Why? Because you have fulfilled your task
regarding food safety: assuming responsi-
bility and avoiding risk.
European Regulation EC 2023/2006 (GMP)
requires quality assurance but lacks concrete
details or rules of realizing it in prac-
tice. Fact is, nevertheless, that those who sell
rPET packaging with direct food contact in the
European market will be audited by a Mem-
ber State Authority in future. A task force,
established for this purpose and consisting
of several Member State Experts, is currently
developing a guideline for these audits. There
are no details available so far, but the basis for
such controls will be a transparent description
of how traceability and quality are assured.
How to organize this in practice?
The premise for traceability is deep knowledge
about your material. You can only gain that
knowledge through strict quality control.
A few examples: At each raw material delivery
data sheets can be checked. They serve as evi-
dence for sorting purity (5% non-food applica-
tion limit) and material origin (manufactured in
correspondence to European Legislation). Input
material analysis, e.g. a sample of each truck
load, confirms pre-established input material
specifications. The “roast test” is a useful way
of identifying and quantifying non-volatile im-
purities like PVC, metal parts or the like in the
input material. Gas chromatography provides
valuable information about volatile compounds
like AA and Limonene. Effected before and
after the super-cleaning process on a regular
basis, they can also serve as indication for the
efficiency of the recycling process. Finally, also
the storage of tested material samples is part
of the quality control. The storage period is
recommended to correspond to the shelf life
of the packed product.
That is, regular quality control that covers sup-
plier checks, input and output material tests, as
well as sample storage combined with suppor-
ting documentation serves as evidence for trace-
ability and contributes to a safe final product.
IFNo matter if it is food grade lake, sheet or tray – please ask yourself
two questions:
#1 Do I know
which input mater ial f rom
which supplier ended up in this product?
#2 Am I able to show
any k ind of documentation that conf irms
the or igin?
SUPPORT ING DOCUMENTS
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PPORT ING DOCUMENTS
SUPPORT IN
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SUPPORTING DOCUMENTS
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03
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INCOMING WASHED
FLAKES CHECK
- Origin
- 5% non-food limit
STORAGE
Material and sample
storage with accura-
te labelling
MATERIAL QUALITY
CHECK
- iV, color, GC
- Comparison to
food grade spec
BIG BAG
LABELLING &
TESTING
- One Analysis per
BB (Roast test, GC)
- Comparison to
input spec
SUPER-CLEANING PROCESS
Food grade parameters check
THE FIVE STEPS TO TRACEABILITY
