Start with responsibility and intended use
Product-contact machinery parts, hoses, seals, lubricants and packaging materials must be suitable for their intended food contact, temperature, time and cleaning conditions. Supplier declarations should match the actual application. Define who supplies, integrates, installs, owns and uses the equipment, and record the final product, packaging, environment, operator tasks and maintenance interventions. A generic certificate or checklist cannot replace that project-specific scope.
Questions for the project team
- Which machine parts and packaging components contact the food directly or indirectly?
- What food type, temperature, contact time and cleaning chemistry apply?
- Are material declarations and traceability available for the supplied configuration?
- How will wear, replacement parts, lubricants and modifications remain controlled?
Documents and evidence to plan
The exact records depend on the project, but the following deliverables provide a practical starting structure:
- product-contact material schedule
- supplier declarations and traceability
- food, temperature and cleaning compatibility review
- approved lubricant and spare-parts controls
- change-control and inspection records
Apply the controls across the machinery lifecycle
Review the requirement during specification, supplier selection, design review, factory testing, installation, site acceptance, training, routine operation, cleaning, maintenance and modification. A change that appears small—such as a new solvent, bottle size, cap, guarding opening, extraction system or line speed—can alter the original risk or conformity basis.
Current official sources
Use the official sources below as the starting point and check their update dates when the project is reviewed.
Common questions
What is the starting point for food-contact material planning for packaging lines?
Product-contact machinery parts, hoses, seals, lubricants and packaging materials must be suitable for their intended food contact, temperature, time and cleaning conditions. Supplier declarations should match the actual application.
Does a conformity mark replace the user risk assessment?
No. Supply obligations and duties for safe installation, use, inspection, maintenance and workplace risk control are related but distinct.
Who should confirm the legal interpretation?
Use current official guidance and competent legal, safety, engineering, metrology or food-safety advice appropriate to the project and jurisdiction.
When should the assessment be reviewed?
Review it when equipment, product, packaging, formulation, process, controls, room layout, use or official requirements change, and after relevant incidents or findings.