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

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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
Figure 2 Compliance Assessment Scheme for converting operations Incoming Materials Paper & Board • Declaration of Compliance Ancillary Materials (these are principally inks and adhesives) • Compliance monitoring • Use of International, European or National standards recommended when available (plus BfR and FDA where relevant) • For Printing Inks application of the EuPIA Guideline is required Process • GMP Usually based on ISO 9001 and supported as appropriate by hygiene management sytems • Traceability Guidelines Finished Product • As relevant, “design-type” assessment of suitability (See Clause 8) •Purity criteria of the final product according to the ancillary materials added. Review of compliance 29
Page 1: FoodContact Industry Guideline for
Page 4 and 5: TABLE OF CONTENTS Foreword 1 1. Int
Page 6 and 7: This Guideline considers the specif
Page 8 and 9: 1 1.1 Objective Introduction This d
Page 10 and 11: 2.2 Demonstration of Compliance In
Page 12 and 13: 4 CHEMICAL Chemical TESTING Testing
Page 14 and 15: 5 If the packaging to food ratio di
Page 16 and 17: 6 Best practice for treatments appl
Page 18 and 19: 7.2 Requirements 7.2.1 Requirements
Page 20 and 21: 9 Traceability Guidelines Business
Page 22 and 23: References Annexes Annex 1: List of
Page 24 and 25: Annex 2 REQUIREMENTS FOR RECOVERED
Page 26 and 27: Annex 3 testing methods As a genera
Page 28 and 29: Annex 4 Declaration of Compliance T
Page 30 and 31: In these latter cases paper and boa
Page 34: Figure 3 ELEMENTS OF THE DETERMINAT

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

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