SAFEGUARDS | Hardgoods NO. 100/15

SafeGuardS mother food contacts

Brazil's National Health Surveillance Agency (ANVISA) has notified the World Trade Organization’s (WTO) Committee on Technical Barriers to Trade of a draft Technical Resolution, establishing Good Manufacturing Practices (GMP) for companies that manufacture direct-food-contact packaging (intermediate materials producers are exempted). All manufactures must comply with this regulation 18 months after its official release.

GMP [1] requirements are a fundamental part of the European Union to assure consumer’s health and prevent food contamination coming from food contact materials (FCM). Following this example, the Brazilian ANVISA announced its own requirements on GMP related to on FCM. The major points from the proposed regulations are highlighted below:

  • Detailed requirements are laid out for the design of the buildings and facilities.
  • Equipment, furniture and fixtures shall not release a toxic substance or odours and shall be kept in a clean and operational state.
  • The factory must have a pest control program. Chemical pest control should be employed only when other preventive measures fail, and shall be carried out only by specialized companies, following specific legislation, using compliant products. Pre and post treatment shall take place to avoid contamination of packaging.
  • The cleaning of the production area should be carried out on a predetermined schedule. The products used in cleaning operations must be regulated by the competent body. Odorant and deodorant substances shall not be used to avoid contamination and odour.
  • Employees who present injuries or symptoms of illness that may compromise the sanitary conditions of packaging, equipment or environment should be removed from production work as long as the health conditions persist. Employees must wear a clean uniform that is appropriate for the work performed.
  • The factory must have a sufficient number of dedicated waste containers which are easily cleaned, sanitized and moved. The waste shall be kept in a closed and isolated location away from production. 
  • Manufactures must specify the criteria for evaluation and selection of raw material suppliers. Raw materials shall be received in a protected and clean area. Inspection of raw materials shall be performed and results recorded upon receipt. Raw materials that fail inspection must be returned to the supplier. If they cannot be returned, they must be properly identified and stored separately with the final destination labelled. Any reusable scraps should be frequently collected and stored in an isolated, sanitary location away from production.
  • During production, effective measures must be taken to avoid contamination of the product. For example, if water comes into direct contact with equipment, raw materials or final products, it shall meet the drinking water standard established by the Ministry of Health. The manufacturing process and the maintenance of equipment shall be documented. Quality control of the final product shall be performed to ensure the compliance to sanitary and health legislation.      
  • The packaging manufacturers must develop and implement a Manual of Good Manufacturing Practices that includes Standard Operating Procedures (SOP). The SOP shall be monitored and reviewed whenever necessary, and made available to operators and health authorities.
  • The technicians responsible for the production process must be trained and have knowledge of hygiene and good manufacturing practices. While the production area employees must be trained at least the following subjects: the production process,  hygiene, good manufacturing practices and knowledge of toxicity in the care and handling of raw materials and finished products.
  • A check list is also provided for the implementation of GMP measures.

With food safety services located in over 60 countries worldwide, SGS is one of the leading providers of brand protection and risk management services to food producers, manufacturers, distributors, retailers and hospitality service providers. Maintaining integrity in the supply chain is at the core of our vision and values. With a holistic approach to product and process safety and quality, our renowned global network of field, laboratory and project management staff work with industry leaders to help reduce their risk of producing and/or selling defective and contaminated product. For further information on our full range of services, please contact your SGS local office or visit our website

For enquiries, please contact:

Samuel Lee
Global Competence Support Centre, Food Contact Material committee
t: +86-20-3213 6200

© SGS Group Management SA – 2015– All rights reserved - SGS is a registered trademark of SGS Group Management SA. This is a publication of SGS, except for 3rd parties’ contents submitted or licensed for use by SGS. SGS neither endorses nor disapproves said 3rd parties contents. This publication is intended to provide technical information and shall not be considered an exhaustive treatment of any subject treated. It is strictly educational and does not replace any legal requirements or applicable regulations. It is not intended to constitute consulting or professional advice. The information contained herein is provided “as is” and SGS does not warrant that it will be error-free or will meet any particular criteria of performance or quality. Do not quote or refer any information herein without SGS’s prior written consent.