Packaging Materials Certificate for Canadian Market
I have a question about packaging. We make composite cans and we sell them to several companies. One in-particular then sells them to Canada. I am in the USA. Our letter reads
"
All materials, products and packaging that have been manufactured, prepared, packaged, labeled, provided to, sold or held for our customers and all their subsidiaries by "Name Of Company", are in conformance to all United States requirements, including the U.S. FDA Food Contact Substance Requirement and 21 Code of Federal Regulations Part 110, and have not been adulterated or misbranded within the meaning of the Federal Food, Drug &Cosmetic Act as amended. This guarantee includes all products which fall within the definitions contained in the above stated act.
Our issue is that they are asking:
This certificate makes no mention of acceptability for food contact purposes nor does it reference Health Canada requirements. Please have your vendor revise their letter to include.
I am unsure how to respond to this. Part 110 of Code 21 for the FDA should explain it all to them from how i read it. Any help would be appreciated!
Hi Brian,
You can also reference the "Reference Listing of Accepted Construction Materials, Packaging Materials and Non-Food Chemical Products", however, this database is no longer being updated. If you find something on that list, it is still approved, only new products will not be added to the list.
If you have a new product you want added to the list, you can request a Letter of No Objection from CFIA or Health Canada (Bureau of Chemical Safety).
You could also get a letter of guarantee from the supplier with the following information:
According to FSEP requirements, you need to be able to provide information that the packaging material complies with Part B, Division 23 of the Canadian Food & Drug Regulations.
If you cannot get this, you could provide the auditor or customer with a statement indicating you or the supplier will provide supporting documnets that the packaging material meets requirements from another country if requested by CFIA. The FDA statement you mentioned may be sufficient if you can provide the supporting documentation as to why to packaging is compliant to the FDA standards.
If you look up the FSEP manual online, you can find the info I just listed under the B.2.1.1 bullet.
Hope that helps.
Helped a lot! Thank you very much.