Traceability and conformity declarations: the duties of packaging producers

To clarify

Cured by  Esseoquattro’s Quality Office

We became familiar with article 3 from EC Regulation 1935/2004 according to which MOCAs (food contact material rules) have to be produced conformingly to the good manufacturing practices and they do not have to transfer the product substances that could deteriorate or modify its organoleptic characteristics.

How can we be sure to respect these conditions?

It’s necessary to run a detailed and deep evaluation of the risk, which involves not only the execution of migration analysis and screening of the finished product, the control of the production process and the labelling, but also it requires the complete traceability of the product and the correct compilation of both the declaration of conformity and the supporting documentation.

Let’s see what these last points mean.


With tracking we mean that process that keeps track of all the input elements that create, modify or transform a product; with tracing we mean that process that moves backwords in the production chain, to look for a precise event or action. Both follow the logic of orderly collecting of information that leads to the creation of the product and allows the backward verification of each action carried out.

Tracking and tracing of materials and objects are guaranteed in Esseoquattro in all the production phases, from receiving the primary materials, to the controlling of production, to the withdrawal to any defecting products, to the management of information sent to consumers to the attribution of responsibilities.

MOCA producers dispose of systems and procedures that consent the individuation, from the batch of the product made, to all of the components that make up the packaging, up to the incoming raw materials. All this information is available to the competent authorities if they ever request it.

In order to guarantee the traceability of its products, Esseoquattro chose to adopt a specific pattern for both paper bags and paper sheets.

With this data it is easy to go back and find out the exact moment in which the packaging was made, and from here the raw materials used for its production: paper, glue, inks; not only, we are perfectly capable of finding out the staff, the equipment used, the process parameters set.

All this data is grouped in our IT management system.

Conformity declaration

MOCA must be accompanied by a written declaration that certifies its conformity and in order to demonstrate it, it is necessary to have an adequate support documentation (available to the controlling authorities).

It is issued by the Packaging Manufacturer.

There are no legislative texts that could indicate a deadline for this declaration, usually the updating periodicity is decided between the parties and it is recommended to carry out a review every one or two years or whenever changes are made to the article object of the declaration.

Materials and objects that are to be in contact with food substances must always be accompanied by this declaration and the violators of this provision will be punished with an administrative pecuniary sanction.

Producers, of course, must control periodically, through analysis credited by certified laboratories, what written in the conformity declaration: all of the conducted analysis, the laboratory documents, the University etc., will represent the support documentation that has to result updated, and available to competent authorities.

“Waterfall effect” of the Conformity Declaration:

Primary materials manufacturer ► RELEASES


User/Final distributor ► HOLDS

Any dealer or wholesaler that enters these categories, always has to release/detain the conformity declaration MOCA.