Assurance of compliance within the production chain of food contact materials by good manufacturing practice and documentation – Part 3: Lids for glass jars as an example

Parts 1 and 2 of this work outlined the background and the general terms of assuring compliance of food contact materials (FCM) with European legislation by good manufacturing practice (GMP) and compliance declaration (CD). All stages of the manufacturing process are engaged in GMP defined as the process to achieve compliance of the final product with Article 3 of the Framework Regulation 1935/2004 and the specific legislation derived there from. For each relevant aspect, either compliance is concluded (explicitly stating compliance if this is required) or compliance work is delegated to later stages of manufacturing by corresponding instructions in the documentation accompanying the product. A compliance box (CB) is proposed to structure the process and the documentation. Here it is applied to metal closures for glass jars, which are internally coated and contain a gasket of plasticized PVC. A specific composition is assumed and possible compliance work discussed to illustrate how the system is conceived. The system is tested by the problems and issues concerning these lids during the last 10 years: indeed, most of them would have been avoided.