Harvested Product Packaging Materials
If harvested product is stored in harvested product packaging materials and these are used to store equipment after they are empty – is this acceptable? What if adjacent harvested product packaging materials still contain product? They would be separated only by wooden walls.
Section 17.2 (Use of Packaging Materials) states for Harvested Product Packaging Materials that operations use materials that are clean and free of debris (e.g., from other crops, compostable waste, garbage) and have not been used for any other purpose that may be a source of contamination (e.g., to carry tools, personal effects, cleaning agents, agricultural chemicals, maintenance materials or previously used to harvest other crops where agricultural chemical residues may contaminate product). Therefore, it depends on what type of equipment is being stored in them and if it is a source of contamination (e.g., leaking oil, lubricants, etc.). Also, Section 20.1 (Storage Conditions for Harvested Product) requires that harvested product is in an environment that does not contaminate the product or the containers they are in (e.g., clean and well-maintained storage area) and is separate from market product, equipment, fuels, agricultural chemicals (including treated seed) and market ready packaging materials. The definition of separate is “not on top of, underneath, or touching”. Therefore, it is acceptable that these are in the same area as long as they are not a source of contamination to the product (e.g., leaking oil from the equipment, etc.).
Market Ready Packaging Materials
If a plastic container is being used inside a cardboard master to hold berries and keep them in good condition during transport, does this plastic container need to be labelled?
In this case, the plastic containers would fall under ‘trays’ within the definition of packaging accessories. Packaging accessories are used to fasten, contain, protect, or identify product or packaging material. These flexible plastic containers used for berries would be similar to cardboard trays that are placed in apple boxes to ensure apples are not bruised.
The plastic containers used inside cardboard masters to hold berries during transport are not the same as the usual, often more rigid plastic pints or quarts used to sell berries to the end consumer; therefore, they do not need to be considered as primary market ready packaging materials.
Since these plastic containers used inside cardboard masters are considered as packaging accessories, they are NOT required to be labelled with anything (unique identifier, lot code, name, address, etc.). Instead, the traceability requirements would apply only to the cardboard master.
|Flexible plastic containers
(considered packaging accessories)
Rigid plastic containers
(considered primary market ready packaging materials)
What sort of identifying information (e.g., name, address) is required for the labelling of market ready packaging materials?
According to Section 17. Packaging Materials of the CanadaGAP manual, market ready packaging materials must be labelled with:
- The correct identifying information (i.e., name and address) of:
- The operation that produced the product, OR
- The operation that packaged the product, OR
- The company for whom it was produced/packaged
More information on where and how these materials need to be labelled, as well as details on the other aspects of labelling, can be found in Section 17. Operations need to read what is expected for both primary and secondary market ready packaging materials and to look at their own packaging materials in order to determine what labelling is required for their situation.
The requirement above has similar wording to the Safe Food for Canadians Regulations (SFCR) which state (Part 11: Labelling requirements for fresh fruits and vegetables):
The name and principal place of business of the person (definition) by or for whom prepackaged fresh fruits or vegetables are manufactured, prepared, produced, stored, packaged or labelled must be declared on the label.
The following guidance is given within the SFCR to outline what is meant by ‘principal place of business’:
The principal place of business must lead to a physical location where the “principal”, or main, “business” can be found. Although a physical location is required to be declared on labels, the legislation does not prescribe the level of detail necessary, nor does it state that a “complete mailing address” is required. The CFIA encourages industry to provide a mailing address that is complete enough so that consumers, who wish to communicate with the “person” in writing, can do so in a timely manner. The best practice is to include the civic address, city, province, postal code and country.
Websites, telephone numbers, and virtual addresses are not acceptable “principal place of business” declarations, as they are not physical locations. Websites are instead examples of Additional information that may be included on a label.
More information on the labelling requirements within the SFCR can be found here: https://inspection.canada.ca/food-label-requirements/labelling/industry/fresh-fruits-and-vegetables/eng/1393800946775/1393801047506?chap=6.June 28th, 2021 at 09:22 am
Lot code is defined in the CanadaGAP Food Safety Manuals as:
A code that can be used to identify a lot that was manufactured, prepared, produced, stored, graded, packaged or labelled, under the same conditions. A lot code can be numeric, alphabetic or alphanumeric. Examples of lot code include: production date, best before date, establishment number, or CFIA SFCR licence number. In addition, the lot code may also be the harvest date, grower identification number, growing region or any other code that may be used for traceability purposes.
CanadaGAP has a training note available here regarding Lot Code that provides further information on the requirements. This training note contains information on why the Lot Code requirements have been added, where they are found in the manual, and general guidance to follow.
The Canadian Produce Marketing Association (CPMA) has developed a guidance document available on their website at: https://cpma.ca/docs/default-source/industry/traceability_guidance_document_for_industry_compliance_with-the_sfcr.pdf. This is a fantastic resource for operations looking for more guidance on how to meet Lot Code requirements. Within this document there is also an excellent decision tree to help operations determine if their product requires a Lot Code, as well as many visuals and practical examples that provide clarification about Lot Code requirements.
An operation that is packing puts a blue sticker with an X on it (in their records this indicates it was packed during the week of April 7-14) and writes ‘PJ’ (in their records, this represents the initials of the owner of the operation that produced the product) on their secondary packaging materials. Is this fulfilling the requirement for Pack ID?
Yes. The definition for Pack ID in the glossary is the following: “Information identifying 1) who produced the product and 2) when the product is packed/repacked. Linked to Lot ID for complete traceability”. The person who produced the product in this case is Paul Jones (PJ). The product was packed during the week of April 7 -14 which fulfills the requirement for when it was packed. This does NOT have to be a date. It is up to the operation to determine the “when” – it may be an hour, a week, a month, etc. It is, however, in the operation’s best interest to narrow down the “when” as in the case of a recall the least amount of product affected, the better. Section 17.2 (Use of Packaging Materials) requires that the Pack ID be on the secondary packaging materials unless there are no secondary packaging materials, then it would be on the primary packaging materials. If there are no primary packaging materials, then the Pack ID would be on the pallet or skid.
If product is labelled individually (e.g., with a barcode stamp or sticker corresponding to records within the operation that identify who produced the product and the packing date), does the box still need to be labelled with Pack ID?
No, in this situation the operation would not be required to have the Pack ID on the boxes. The requirement in Section 17.2 (Use of Packaging Materials) requires a Pack ID on market ready packaging material under the assumption that the operation is not able to put it on the actual product. If this information is on the actual product, this is even better for traceability and fulfils the requirements.
As per Section 17.2, the box would still need to be labelled [unless the secondary container is transparent (e.g., a large clear plastic bag holding smaller labelled bags of carrots)] with the correct identifying information (i.e., name and address) of the operation that produced the product, OR the operation that packaged the product, OR the company for whom it was produced/packaged. This is a requirement as well as a federal regulation.