Packaging Guide

So, you’ve made your goods and you are ready to ship them. You may think that it’s a simple matter to use any old pallet or crate and send them off. In fact nowadays packaging is not that simple.

Packaging regulations and customer requirements now frequently demand specialist attention, both in the UK and abroad.

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If you are in the food or pharmaceutical business your customers will be looking very closely at the health and safety of the packaging you use. Pallets may carry diseases including E Coli. This leads to demands for treated hygienic plastic pallets and boxes, or at least heat treated wooden ones. And when you begin to export, the challenges are greater still.

International Packaging Regulations

Wooden packaging
Wooden pallets (also packing crates, drums etc.) dominate the worldwide market. Growing trees sustainably for pallet making is environmentally responsible. Wooden pallets get 8 trips on average before being repaired or broken up. The broken ones can form part of new pallets or be recycled into chipboard, biomass or garden mulch.

The International Plant Protection Committee (IPPC) has a regulation about the phytosanitary standard for wood packaging, known as ISPM15. The purpose of this is to restrict the spread of wood-borne pests such as Pine Wood Nematode and Asian Longhorn Beetle. These can be found in untreated packaging.

Anyone exporting to countries outside the EU should abide by ISPM15 and insist that their pallets and creates carry its unique stamp: although not all countries have adopted the standard, it is an increasing trend and the costs of a Customs rejection or local treatment of the packaging can be very severe.

Treatment can take the form of Heat Treatment (coded HT) or Fumigation by methyl bromide (MB): however MB has been banned in the EU since March 2010 so in practice, heat treatment is the method to choose.

However, life is rarely that simple and you should get professional help from your freight forwarders on what local regulations are at any given time. For example, Australia has brought in a requirement to treat a particular pest that means that UK exporters are recommended to get their pallets etc. kiln-dried to <20% moisture in addition to heat treatment, and add the KD code. And in Portugal, there is a nematode risk so exporters and importers are recommended to adopt ISPM15 for this country.

The advice to users of pallets is to use a Timber Packaging & Pallet Confederation (TIMCON) member, registered with the Forestry Commission.

Exempt from the regulation are manufactured wood by-products such as fibreboard (plywood), orientated strand board (OSB) and chipboard. Plastic and metal pallets are also exempt.

The heavier 4-way entry pallets are longer-lasting than simple 2-way ones: 4-way pallets are often supplied by rental/return networks such as Chep, whose blue-painted pallets may be seen all around Europe. They maintain the quality of recycled pallets and are often specified by end users.

Plastic packaging
These pallets and boxes are long-lasting, stackable and can easily be made hygienic. Some are made from recycled PET drinks bottles. There are heavy-duty versions for racking use, and lightweight ones that are ideal for airfreight. APME administers a European plastic pallet re-use scheme.

The disadvantage is the cost, up to 10 times the price of wooden pallets. They are also fire hazards, being easily to catch light and emitting dangerous toxins.

Guide

Metal packaging
This comprises pallets for specialist uses, including the military, automotive and tyre industries. They represent less than 1% of the market.

Standard steel pallets are strong but expensive and heavy, and they rust over time. Aluminium ones are also strong but lighter, and are good for airfreight. Stainless steel pallets are used for clean room applications. Both are 2 to 3 times the price of regular steel.

Pallet sizes

There is no universal standard, much to the annoyance of freight forwarders and shippers, but there are 6 recognised ISO sizes:

1016 x 1219 mm (40” x 48”) North America
1000 x 1200 mm Europe, Asia (in practice very similar to the North American one)
1165 x 1165 mm Australia (it fits their trains)
1067 x 1067 mm (42” x 42”) Worldwide
1100 x 1100 mm (43” x 43”) Asia
800 x 1200 mm Europe (the best-known ‘Europallet’ size, designed to go through a standard door)

The other recognised size in North America is the widely-used American Grocery Manufacturers’ Association (GMA) 50” x 48”partial 4-way pallet.

Professional assistance

Packaging guidelines usps

Your freight forwarder may well be able to help you with arranging various aspects of packaging, which can include the selection of pallet type and size, palletising goods, creating and filling crates, ensuring compliance with export regulations and expert packaging (a specialist job in itself but one which pays back in terms of avoiding damage en route and rejections at the port of receipt).

Don’t be tempted to skimp on this very important function or your business may suffer.

Issued by:

September 1994; Revised April 2008; Revised October 2009; Revised January 2013

This guidance represents the Food and Drug Administration's (FDA's) current thinking on this topic. It does not create or confer any rights for or on any person and does not operate to bind FDA or the public. You can use an alternative approach if the approach satisfies the requirements of the applicable statutes and regulations. If you want to discuss an alternative approach, contact the FDA staff responsible for implementing this guidance. If you cannot identify the appropriate FDA staff, call the appropriate telephone number listed on the title page of this guidance.

Introduction

In a guide such as this, it is impractical to attempt to answer every food labeling question that might arise. The most frequently raised questions have been addressed using a “question and answer” format. We believe the vast majority of food labeling questions are answered. They are grouped by the food labeling area of interest. The Table of Contents will help you locate your food labeling area of interest.

Under FDA's laws and regulations, FDA does not pre-approve labels for food products. Questions concerning the labeling of food products may be directed to the Food Labeling and Standards Staff (HFS-820), Office of Nutrition, Labeling, and Dietary Supplements, Center for Food Safety and Applied Nutrition, Food and Drug Administration, 5001 Campus Drive, College Park, MD 20740-3835, Telephone: (240) 402-2371.

Background

The Food and Drug Administration (FDA) is responsible for assuring that foods sold in the United States are safe, wholesome and properly labeled. This applies to foods produced domestically, as well as foods from foreign countries. The Federal Food, Drug, and Cosmetic Act (FD&C Act) and the Fair Packaging and Labeling Act are the Federal laws governing food products under FDA's jurisdiction.

The FDA receives many questions from manufacturers, distributors, and importers about the proper labeling of their food products. This guidance is a summary of the required statements that must appear on food labels under these laws and their regulations. To help minimize legal action and delays, it is recommended that manufacturers and importers become fully informed about the applicable laws and regulations before offering foods for distribution in the United States.

The Nutrition Labeling and Education Act (NLEA), which amended the FD&C Act requires most foods to bear nutrition labeling and requires food labels that bear nutrient content claims and certain health messages to comply with specific requirements. Although final regulations have been established and are reflected in this guidance, regulations are frequently changed. It is the responsibility for the food industry to remain current with the legal requirements for food labeling. All new regulations are published in the Federal Register (FR) prior to their effective date and compiled annually in Title 21 of the Code of Federal Regulations (CFR).

This document supersedes the previous version issued in October 2009.

Resources

Note on Nutrition Labeling

The Food Labeling Guide’s Chapter 7 about Nutrition Labeling is currently under revision and does not reflect all of the most up-to-date labeling requirements.

Until the guide is updated, please refer to the Nutrition Facts label final rule for information about updating nutrition labels. You also can consult FDA’s Industry Resources.

Contact Us

Packaging Guide

Office of Nutrition and Food Labeling, HFS-800
Center for Food Safety and Applied Nutrition
Food and Drug Administration
5001 Campus Drive
College Park, MD 20740
(Tel) 240-402-2373

Translations

Packaging

This document is available in several foreign language(s). FDA offers these translations as a service to a broad international audience. We hope that you find these translations useful. While the agency has attempted to obtain translations that are as faithful as possible to the English version, we recognize that the translated versions may not be as precise, clear, or complete as the English version. The official version of this document is the English version. The translations are of the October 2009 version. FDA has archived the following translations as they are no longer up to date:

Packaging Guidelines Amazon

Submit Comments

Submit comments on this guidance document electronically via docket ID: FDA-2013-S-0610 - Specific Electronic Submissions Intended For FDA's Dockets Management Staff (i.e., Citizen Petitions, Draft Proposed Guidance Documents, Variances, and other administrative record submissions)

Packaging Guidelines For Canvas Frames

If unable to submit comments online, please mail written comments to:

Packaging

Dockets Management
Food and Drug Administration
5630 Fishers Lane, Rm 1061
Rockville, MD 20852

Packaging Guide

All comments should be identified with the title of the guidance.

Packaging Guideline

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