ISO 22000 by industry
ISO 22000 for packaging: what brand owners, fillers and auditors expect of a food packaging manufacturer
Clause by clause: ISO 22000:2018 requirements: every clause explained →
What changes when the organisation makes food packaging: why brand owners ask, what belongs in a converting site's scope, where auditors sample migration, inks, foreign matter and hygiene zoning, and how the system carries into FSSC 22000 or BRCGS Packaging Materials.
Key points
- Brand owners and fillers ask converters for ISO 22000 because food-contact packaging carries its own hazards: migration, ink set-off, taint and foreign matter.
- The standard's own scope names suppliers of packaging materials and other food contact materials; the prerequisite programmes for a converting site sit in ISO 22002-4:2025, used with ISO 22002-100:2025.
- Auditors test food-contact declarations, ink and adhesive controls, foreign matter and hygiene zoning on the press hall floor.
- Where a customer specifies a GFSI-recognised certificate, the routes are FSSC 22000 for packaging or BRCGS Packaging Materials, and an ISO 22000 system carries into either.
Why packaging manufacturers are asked for ISO 22000
The request normally arrives from the technical or procurement team of a brand owner, a filler or a co-packer. It comes with a supplier questionnaire, a specification to sign and a request for food-contact declarations. For a converter, the certificate shows that the site treats its output as part of the food.
Many brand owners write "GFSI-recognised certification" into their supplier programmes. ISO 22000 alone does not carry that recognition. FSSC 22000, built on ISO 22000, has a food chain category for the production of packaging material, and BRCGS Packaging Materials is the retailer-led alternative. The choice between routes is covered in HACCP vs ISO 22000 vs FSSC 22000: which one, and when.
Scope for a packaging converting site
A usable scope names the site and the product families in the terms a buyer reads on a purchase order: printed and laminated films for snacks, beverage cans, glass bottles, folding cartons or moulded closures. Everything that can affect the food safety of those products belongs inside: material and ink intake, printing, coating, lamination, forming, the laboratory and finished goods storage.
Outsourced steps stay the site's responsibility. If a trade printer takes overflow work or a laboratory runs migration tests, the converter defines and verifies its controls over each.
Three scope mistakes recur in this sector: leaving out a second press hall or a satellite store whose output ships under the certificate; excluding non-food-contact ranges that share presses, inks and cleaning with food-contact work; and describing the range so broadly that the food chain category no longer fits. The general rules are in ISO 22000 scope: sites, products and processes, and the mistakes that cost you.
Where the requirements bite in packaging manufacture
| Requirement area | What it means on a converting site | Evidence the auditor samples |
|---|---|---|
| Hazard analysis for packaging | Chemical hazards such as migration, set-off and residual solvent, physical hazards such as glass, metal and splinters, and taint, assessed at each step of a verified flow diagram | Flow diagrams walked on the floor, a reasoned hazard analysis by product family, and the control measures it selects |
| Food-contact declarations and customer specifications | The raw materials and finished pack meet the food-contact requirements the customer and the applicable law set, | Supplier declarations for resins, inks, adhesives and coatings, migration test reports, signed customer specifications, a record of which declaration covers which product |
| Inks, adhesives and coatings | Only approved, food-contact-suitable chemistry on food-contact work, with curing and drying controlled | Approved materials list, ink and adhesive batch records, cure or drying checks, residual solvent or odour results where applicable |
| Foreign-matter control | Glass and brittle plastic, blades, wood and loose items controlled around open product; detection or inspection where the hazard analysis requires it | Glass and brittle materials register with audits, blade control logs, detector or vision system checks, breakage records |
| Hygiene zoning and PRPs | Premises, pest control, cleaning, personnel hygiene and zoning around exposed food-contact surfaces, selected against ISO 22002-4:2025 and ISO 22002-100:2025 | Zoning plan, cleaning schedules and verification, pest trend reports, hygiene inspection records, protection of finished reels and pallets |
Two further areas decide many audits: traceability from material lot to customer delivery, proved by a mock recall, and line clearance at job change so the previous job's print or material never reaches a customer. The PRP detail sits in Prerequisite programmes and ISO 22002-1: what a plant needs, and the method in Hazard analysis, OPRPs and CCPs: the hazard control plan.
Customer codes, food-contact law and packaging schemes
A converter answers to several parties at once: the food-contact law of each market it supplies, the packaging codes and specifications of its brand-owner customers, and, where demanded, a GFSI-recognised scheme. One system serves all of them when declarations, migration evidence, PRPs and traceability are held once as shared records.
FSSC 22000 adds the ISO 22002-4:2025 PRPs and its additional requirements to ISO 22000, so the step up is an extension, not a rebuild. BRCGS Packaging Materials is a separate, more prescriptive standard; an ISO 22000 system still supplies much of its evidence. Many converters also hold ISO 9001, and running the two as one system is covered in Integrating ISO 22000 with ISO 9001 and ISO 14001: one system, one audit.
What a packaging engagement looks like
Duration depends on the number of product families, whether the PRPs need works such as zoning or glass control, how complete the declarations and migration evidence are, and how long the site must run to build records. The food safety team leader, production, print and colour, the laboratory, purchasing, engineering and warehouse all take part. With Design™, Sterling guides your food safety team to build and own the system; with Drive™, Sterling carries more of the documentation, internal audit and readiness work so the presses keep running.
How Sterling works with packaging manufacturers
A food safety system your press hall can defend.
Our expert and experienced consultants build the system around your flow diagrams, food-contact declarations, ink controls and hygiene zones, then test it with a mock recall and internal audit before the certification body arrives. Records live in Effivity, included with the engagement, at no additional cost. Sterling does not certify; an independent, accredited certification body audits and decides. We ensure successful certification for our clients.
Book a free discovery callISO 22000 for packaging: questions buyers ask
Can a packaging manufacturer get ISO 22000 certification?
Yes. ISO 22000 applies to every organisation in the food chain, and its scope names suppliers of packaging materials and other food contact materials among them, so a converter can be certified for the packaging it makes.
Which PRP standard applies to ISO 22000 certification for packaging?
ISO 22002-4:2025, the part for food packaging manufacturing, used together with ISO 22002-100:2025 for the common requirements across the food, feed and packaging chain. It replaces the earlier technical specification for packaging.
Does ISO 22000 require migration testing of our packaging?
It requires you to identify migration as a hazard and control it, and the evidence normally includes supplier declarations and migration test results for the intended food and use conditions. The market's food-contact law and the customer's specification set what is tested, and to which limits.
Our customer asks for BRCGS Packaging or FSSC 22000: is ISO 22000 still worth doing?
Yes, as a foundation. FSSC 22000 is ISO 22000 plus the packaging PRPs and additional requirements, and the same system supplies much of what BRCGS Packaging Materials asks for.
ISO 22000 by industry
Every guide in the ISO 22000 series is written for one question and links back to the hub for the whole picture.
- ISO 22000 for catering, hotels and food service
- Effivity for ISO 22000
- ISO 22000 for feed and animal food production
- ISO 22000 for food and beverage manufacturing
- ISO 22000 for food packaging manufacturing
- ISO 22000 gap analysis
- HACCP vs ISO 22000 vs FSSC 22000
- Hazard analysis, OPRPs and CCPs
- ISO 22000 for ingredients, additives and supplements
- ISO 22000 for retail and wholesale
- ISO 22000 for transport, storage and distribution
Keep exploring
Explore more about ISO 22000
Watch a video on how to implement ISO 22000 here.
Watch a video on ISO 22000 requirements here.
ISO 22000 resources
Services for ISO 22000
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