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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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