Why Customers Ask for It
Food and consumer goods brands need confidence that printed packaging will not contaminate or mislead. Packaging that touches food falls under food contact rules, such as the FDA's food contact regulations in 21 CFR, and brands often require a recognized certification such as BRCGS Packaging Materials or an equivalent GFSI-benchmarked scheme from suppliers. Pharmaceutical packaging customers may ask for ISO 15378 or similar controls.
Check what each customer actually requires in its supplier agreement, since certification scope and hygiene levels differ by product risk, for example high-risk areas for packaging in direct food contact versus lower risk secondary packaging.
Hazard Analysis for Print and Converting
The standard expects a documented hazard and risk assessment that fits the products you make. For printers, typical hazards include ink and varnish migration through the substrate, foreign body contamination, odor and taint, wrong artwork or wrong substrate used, and cross contamination between materials. Document how each is controlled on press and in finishing, with monitoring and records.
Low-migration inks, controlled cleaning, metal and glass controls, and proper segregation of food contact materials are typical controls. A hazard analysis written once and never revisited is a common audit finding.
- Ink, varnish and adhesive selection and migration risk for the end use
- Foreign body controls: knives, blades, glass, wood, pests
- Segregation of food contact and non-food contact materials
- Artwork, color and barcode verification before release
Traceability and Mock Recall
Auditors will ask you to trace a finished pallet back to the raw material lots and forward to the customers who received them, within a stated time. Converters often fail this when roll remnants lose their lot identity, when ink batches are not recorded against jobs, or when lot data lives in paper travelers. Your ERP or MIS should hold lot numbers through receipt, slitting, printing, converting and shipping, and you should run mock traces regularly, timing them.
Where the system cannot link a printed roll to its source lot, add a controlled record at the point where the link would otherwise be lost.
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Document Control, Supplier Approval and Specifications
Customer specifications, artwork approvals, work instructions, and supplier approvals all need controlled versions. A press operator must be running the current approved artwork and the current work instruction; an old plate or old spec should be impossible to use. Supplier approval covers substrate, inks, adhesives, plates and outside services, with certificates such as declarations of compliance for food contact kept current.
Many converters keep these in shared folders and spreadsheets, which works until the auditor asks for the version of a specification on a given date. Decide where the controlled copy lives and who can change it.
Where AI Can Help, and a Caution
Auditors ask many questions that need cross-referencing: show me every job in a given month using a particular ink lot, list suppliers with expiring declarations, find all open corrective actions. A private assistant over your ERP, QMS records and document store can answer them quickly with source references, which helps with mock recalls and audit preparation. It does not replace the quality system, a trained food safety lead, or an auditor's judgment, and it should not generate compliance records that nobody verified.
If your volume of food contact work is small and traceability is already clean, the standard tools are enough.
Frequently asked questions
Is BRCGS certification mandatory for packaging printers?
Not by law in general, but many food and consumer brands require it or an equivalent GFSI-benchmarked scheme from their packaging suppliers. Check your customer agreements. Legal requirements such as food contact compliance under FDA regulations apply regardless of certification.
What is a mock recall for a packaging converter?
A mock recall is a timed test where you trace a finished product back to its raw material lots and forward to the customers who received it. Auditors expect you to complete it within a set time and reconcile quantities. Run them regularly so that gaps, such as lost roll lot identity, are found before an audit.
What documents does a converter need for food contact packaging?
Typically a declaration of compliance from material and ink suppliers for the intended use, migration or other supporting data where relevant, specifications for the printed item, and records showing the controls in your process. Exact requirements depend on the product, market and customer, so confirm with your quality lead and customer.
If a mock recall takes your team half a day of folders and spreadsheets, Netray can build a private lookup across lots, jobs and supplier documents so traces come back with sources.