Submission Guidelines for the Acceptability of Novel Packaging Materials

There is a wide variety of packaging materials on the marketplace intended for food use.  These include, cartons, wrapping materials, plastic films, synthetic casings, nettings, trays, pouches, bags and other materials that come into direct contact with the food product (primary packages).

As a general requirement, packaging materials shall not impart any undesirable substance to the food product, either chemically or physically.  Furthermore, they shall protect the food product from contamination (Food and Drug Regulations B.23.001 - No person shall sell any food in a package that may yield to its contents any substance that may be injurious to the health of a consumer of the Food).

Packaging materials with a well established history of safe use or those that are chemically inert, i.e., metal cans, glass containers, etc., are generally exempt from the above-noted submission guidelines (pre-approval process).  Conversely, packaging materials that do not have a well established history of safe food use, i.e., novel, the CFIA will provide manufacturers/importers with a complete evaluation of their acceptability.

Manufacturers/importers are required to prepare a submission that includes the following information:

1. A letter of application or CFIA/ACIA form 2000/06 (you can also request a form by mail or facsimile by contacting Bernard Dallaire (see address below).
2. Complete identification of the material
3. Details pertaining to the intended usage i.e., type of food to be packaged, packaging and storage temperatures, migration studies, etc.
4. Complete chemical composition of the materials, listing the ingredients by percentage.   Each component must be chemically identified and include the trade name and manufacturers.
5. Identification of all chemical agents which are used during the manufacturing process as processing agents but are not components of the finished product.
6. A sample of the material.  The sample should be adequately identified with all the other information provided.  These are to be forwarded free on board (F.O.B.) to the following address (freight, custom duties, brokerage and delivery costs prepaid).

All requests pertaining to the acceptability of packaging materials shall be addressed to:

Bernard Dallaire
Acting, Technical Program Officer
Non-Food Chemical and Container Integrity Programs
Food Safety Division, Ottawa Laboratory (Fallowfield)
Food Safety Risk Analysis Unit
Canadian Food Inspection Agency
1400 Merivale Road
Ottawa, Ontario K1A 0Y9
aa Telephone: 613-773-5840 / fax 773-5642

Note:  The average turn around time for processing of applications is about 8 months.  Therefore, it is strongly recommended that importers/manufacturers of food products, packaged in novel packaging materials, submit their applications at least 8 months before importing/marketing their product(s).

APPLICABLE REGULATIONS:

Food and Drug Regulations

Division 23. Food Packaging Materials

Division 27. Low-Acid Foods Packaged in Hermetically Sealed Containers

Division 28. Novel Foods