Principle

Packaging can be described as the materials used for the protection, preservation and presentation of food products. Product packaging should comply with relevant legislation and conform to agreed specifications. It should be stored in a designated area and in such a way as to minimise contamination or damage. Packaging procedures are a key prerequisite to ensure good manufacturing practice (GMP).

General

24.1 The principles of GMP with regard to packaging have been reviewed in Chapter 10 (10.24–10.35).

Storage

24.2 Packaging materials should be stored in a designated area separate from raw materials and finished products. If open containers are not stored in external packaging, then, where possible, they should be inverted to minimise the risk of product contamination. Packaging liners should be coloured to minimise the risk of product contamination. Stored packing should be shrink‐wrapped together to provide security and stability on the pallet and to minimise the risk of any potential foreign body contamination.

24.3 Packaging materials consist of:

• primary or sales packaging;
• secondary or grouped packaging:
• tertiary or transport packaging; and
• transit packaging.

The main materials that are used for primary, secondary, tertiary and transit packaging include paper, glass, aluminium, steel, plastic and wood. Commission Regulation (EU) No. 10/2011 of 14 January 2011 on plastic materials and articles intended to come into contact with food establishes specific requirements for the manufacture and marketing of plastic materials and articles:

1. intended to come into contact with food;
2. already in contact with food; or
3. which can reasonably be expected to come into contact with food.

Commission Regulation (EU) 2017/752 of 28 April 2017 amends and corrects Regulation (EU) No. 10/2011. Commission Regulation (EU) 2016/1416 of 24 August 2016 also amends and corrects Regulation (EU) No. 10/2011 and comes into force in September 2018. The legislation sets out both specific migration limits (SMLs) and overall migration limits (OMLs) for specific substances and the regulations should be consulted directly for more details.

Packaging materials should be suitable for the food they contain and should be inert during packing, processing, storage and distribution and in preparation by the consumer for consumption, for example microwaving or cooking in the pack. Consideration should also be given to the pH in the case of low‐acid and high‐acid foods and the fat content of the food and whether this will impact on packaging design and suitability. Packaging specifications should be developed and approved for all packaging materials. Packaging specifications may be provided by the customer, especially where own‐label branded products are being supplied or are originated by the manufacturer. Packaging specifications should contain the following information as appropriate:

• supplier name and address and manufacturing site name and address if these are different;
• material composition;
• packaging dimensions, including thickness and gauge;
• specific storage and handling requirements, for example temperature and humidity, single or double stacking;
• material suitability and confirmation of adequate migration testing results and compliance with legislation (see 19.22);
• information on adhesives used if appropriate (see 19.22);
• artwork details, including size of lettering, bar code details, marketing and farm assurance logos and colour standards; and
• promotional information if there is both standard and promotional packaging utilised for the same product.

24.4 Some transit packaging, such as field trays, field bins or retail plastic trays, is reusable/returnable. These trays are used, for example, as a display outer for fresh products, including fresh produce and meat. These trays are sometimes referenced as returnable transit packaging (RTP). While all foods are within primary packaging, it is important that these trays are of a consistently high level of hygiene and cleanliness. It is also important to ensure that all previous tray/box labels are removed before use to ensure that identity and traceability are maintained. Risk assessment should be undertaken with loose food, for example fruits and vegetables that are packed in a tray liner to determine whether the hygiene of the trays could detrimentally affect the food safety and quality of the product. If this is deemed a risk, then suitable controls need to be put in place and verification activities undertaken to determine their continued effectiveness.

24.5 Tray washing between retail outlets and manufacturing plants is often undertaken by third‐party companies. These companies should be subject to the supplier approval and performance monitoring procedure (see Chapter 23). The quality control manager should develop procedures to ensure that retail tray monitoring procedures are implemented to ensure that hygiene levels are maintained and labels have been removed and that appropriate action is taken in the event of non‐compliance.

24.6 Particular attention should be paid to the temperature of the tray wash tank (ideally 75–80 °C) and the rinse tank (ideally 80–85 °C). The Fresh Produce Consortium guide Hygiene Procedures – A Code of Practice for Returnable Transit Packaging at Traywash Units (March 1998) suggests that, based on a maximum number of 1200 trays per hour, trays are exposed to temperatures for the following times:

• wash tank     30 seconds
• detergent rinse  7 seconds
• final rinse    13 seconds

  These temperatures and times should be routinely monitored.

24.7 Retail trays, where possible, should not be stored outside. They should be shrink‐wrapped to minimise contamination.

24.8 Packaging should be stored according to manufacturer’s instructions to minimise damage and possible effects on packaging integrity. For example, reels of laminate packaging need to be stored at the correct conditions and in a way to minimise damage so that the laminate remains intact and does not allow air ingress.

24.9 Heat‐preserved products require the maintenance of packaging integrity to ensure control of product safety and quality characteristics. The quality control manager should develop procedures to monitor packaging integrity and packaging seal quality where this is required, for example in canning, aseptic packing, vacuum packing and gas flushing operations. This will include the need to develop appropriate sampling plans. Protocols for accelerated product durability testing should be developed where appropriate.

24.10 Packaging should be traceable on a batch basis, and the quality control manager or designate should develop a packaging traceability procedure to ensure that control is maintained. Food safety hazards associated with packaging have been discussed (see 9.2, 9.14–9.18 and 19.22). Packaging suppliers should be monitored and approved as per the supplier approval and performance monitoring procedure (see Chapter 23).

24.11 The EC Directive on Packaging Waste (94/62/EC) aims to reduce the volume of packaging waste going to landfill sites by setting targets for the recovery and recycling of packaging waste. The UK legislation that implements the EC Directive is the Producer Responsibility Obligations (Packaging Waste) Regulations 2007 as amended and 2016 amendments¹ (first came into effect in 1997), which cover aspects of recycling and recovery. Guidance on current of requirements and obligations can be found at https://www.gov.uk/guidance/packaging‐producer‐responsibilities.

The Packaging (Essential Requirements) Regulations 2015² (first came into effect in 2003) consolidates and revokes all earlier Regulations that relate to the essential requirements for packaging that is within the heavy metal concentration limits. The essential requirements are:

1. Packaging must be so manufactured that the packaging volume and weight are limited to the minimum adequate amount to maintain the necessary level of safety, hygiene and acceptance for the packed product and for the consumer.
2. Packaging must be designed, produced and commercialised in such a way as to permit its reuse or recovery, including recycling, and to minimise its impact on the environment when packaging waste or residues from packaging waste management operations are disposed of.
3. Packaging must be so manufactured that the presence of noxious and other hazardous substances and materials as constituents of the packaging material or of any of the packaging components is minimised with regard to their presence in emissions, ash or leachate when packaging or residues from management operations or packaging waste are incinerated or landfilled.

The aggregate heavy metal limits apply to cadmium, mercury, lead and hexavalent chromium in packaging or packaging components and require that the total by weight of such metals should not exceed 100 ppm (subject to some exemptions for some products).