Tulip cup step brown (R9160393)

Allergen Management Plan An allergen is a known component which causes physiological reactions due to an immunological response. The list of 14 EU allergens that need to be declared to food businesses in the supply chain and to the consumer through appropriate and accurate labelling are: Celery Cereals containing gluten Crustaceans Egg Fish Lupin Milk Molluscs Mustard Nuts Peanuts Sesame seeds Soya Sulphur Dioxide (Sulphites) Non-food allergens are expected to be managed in a similar way and this would include allergens present in food packaging. At Paper Tech UK the raw materials are not derived from allergens. As part of the HARA study the risk of allergen contamination was considered and the risk is low. The risk assessment of allergen cross contamination would be relevant to allergens brought on site and controls are in place to reduce or eliminate that risk There are no allergen claims made on the product. Paper Tech UK does not manufacture printed materials such as labels Allergen Management plan Paper Tech UK has established, implemented and maintained a plan for the management of allergens to minimise or eliminate the risk of contamination to and/or from the packaging. The risk of allergen cross contamination and implemented controls to reduce or eliminate that risk. Raw Materials It was determined that the raw materials are not derived from allergens. Action plan: This will be assessed when any new type of raw material is sourced (PD016 Specifications and PD017 Supplier Approval procedure) Suppliers Raw material suppliers who hold GFSI certification will have been assessed for allergen controls. Raw materials suppliers complete a complete a supplier questionnaire, which asks whether they supplier has an allergen control policy in place. Action plan: Supplier approval information review (PD017 Supplier Approval procedure) Intake of Raw Materials Reels of paper arrive to the site fully sealed and protected. Action plan: integrity of raw materials is checked and recorded on the Goods Intake (PD001 Goods Intake procedure) During production & Storage at Paper Tech UK Allergen Policy at Paper Tech UK Staff and visitors are not allowed to bring nuts or peanuts on site. This is included in the staff induction and within the visitor’s questionnaire which is completed on arrival to site. Food and drink are only allowed to be consumed in the staff canteen. Food and drink cannot be consumed in the factory, warehouses or locker room. Smoking is only permitted in the external smoking hut. Staff wash their hand on return form break (after consuming food and drink) and on return form a smoking break. Wash hand basin located outside canteen area The Canteen is cleaned daily. Only approved food grade lubricants used on machines (with statement to confirm free of nuts and peanut oil) Action plan: Adherence to allergen control policy is checked as part of the monthly GMP audits (POL 4.9.3.2 Allergen Policy and QCD022 GMP audit) Allergen policy displayed in the staff canteen (POL 4.9.3.2 Allergen Policy) Documented cleaning schedule and records for the canteen (QCD033 Cleaning ancillary areas) Food grade lubricants include allergen (nut / peanut) free declaration. Security / product defence procedures in place to prevent any risk of malicious contamination during production and storage. Cleaning There are no additional cleaning requirements to remove potential risks of allergen contamination. Despatch and distribution to Customer The final product is packed (sealed) and then boxed, so there is no risk of allergen contamination during storage or transportation to customer. Final product allergen claims One product manufactured at Paper Tech UK has a “Gluten Free” claim design. The Paper is printed at Novacart in Italy and then sent to Paper Tech UK for conversion into paper cases. Action plan: Novacart hold BRCGS certification and as such have allergen controls in place. The Gluten Free raw material (paper reel) is fully wrapped when received at Paper Tech UK. The integrity of raw materials is checked and recorded on the Goods Intake (PD001 Goods Intake procedure). No food or drink is consumed within the factory or warehouse, so no risk of the gluten free paper cases being contaminated with gluten. The final product is packed (sealed) and then boxed, so there is no risk of gluten contamination. Review of Allergen Management Plan The allergen management plan shall be reviewed as necessary including when: •There is a change to raw materials or suppliers •There is a change in the manufacturing process •There has been an introduction of new machinery/equipment •There is a change to cleaning practices and procedures If Paper Tech determines that packaging materials, components and/or articles for food contact may contain an allergen identified in law, they will disclose the presence of the allergen to customers. References Annex II of the EU Food Information for Consumers Regulation No.1169/2011 and Commission Delegated Regulation (EU) No. 78/2014 amending Annex II to Regulation (EU) No 1169/2011 https://www.food.gov.uk/business-guidance/allergen-guidance-for-food-businesses https://www.fda.gov/food/food-labeling-nutrition/food-allergies https://ec.europa.eu/jrc/en/publication/articles-journals/allergens-foods

Packaging – Food Contact