Industry guideline for the Compliance of Paper & Board ... - cepi

Figure 1
Compliance Assessment Scheme for papermaking operations
Raw Materials
• Responsible Sourcing system for woodpulp and recovered paper
• Restriction for recovered paper (see Annex 2)
• Chemicals & Additives – only those in Annex 1
Process
• GMP / Hygiene system
• ISO 9001
• Traceability
Compliance
testing for
substances
Refer to substances in Table 1
&
those in Annex 1 (normally BfR Recommendation 36 list)
with restrictions
Substances in Table 1
Substances in Annex 1
Does Table 1 and its notes require
the substance to be chemically
tested in this type of paper or board
for its intended end-use?
No
Yes
Can evidence be produced that the
restriction in Annex 1 cannot be
exceeded (See “Alternatives to
Compliance Testing” in Annex 1)
Yes
No
Can evidence be produces that this
substance cannot occur in this grade or
that migration of this substance to food
could not occur in the envisaged end-use?
Yes
Perform quantitative test
(using Figure 3 if appropriate)
No
Perform test as required in Table 1
(and Figure 3 if appropriate)
Result exceeds
the limit
Result is
within the limit
Result is within
the restriction
Result exceeds
the restriction
28
Failure - the grade is
unsuitable for this end-use
Requirements for
substance satisfied
Failure - the grade is
unsuitable for this end-use