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PAS 223:2011 - 2011

PAS 223:2011 - 2011 is the Prerequisite program and design requirements for food safety in the manufacture and provision of food packaging. This Publicly Available Specification (PAS) outlines the requirements for establishing, implementing and maintaining prerequisite programs (PRPs) and design requirements to assist in controlling food safety hazards in the manufacture of food packaging.

This PAS is applicable to all organizations, regardless of size or complexities that manufacture food packaging. This PAS is not designed or intended for use in other parts of the food chain. Food packaging manufacturing organizations are diverse in nature, and not all of the requirements specified in this PAS apply to an individual organization, so each organization is required to conduct a documented food safety hazard and risk assessment that includes each requirement. Where exclusions are made or alternative measures are implemented, these need to be justified by the food safety hazard and risk assessments, which should be fully documented and supported with technical content.

This PAS is not a management system standard and is intended to be used by food packaging manufacturing organizations that wish to implement PRPs in such a way as to address the requirements specified in BS EN ISO 22000. The contents can however be used by an organization to benchmarks its current systems as part of a continuous improvement process.

This PAS is intended to be used in conjunction with BS EN ISO 22000, not in isolation.

NOTE For the purpose of this PAS, the term food includes beverages.

1 Scope
This PAS specifies requirements to be considered, specifically addressing:

  • Layout and workspace
  • Waste management and removal
  • Storage, utilities and water supply
  • Maintenance
  • Contamination and migration
  • Cleaning and Pest control
  • Personnel Hygiene and Facilities
  • Food packaging information and consumer awareness
  • Food packaging design and development


For the purposes of this PAS, the following terms and definitions apply. It should be noted that the terms and definitions given in BS EN ISO 22000 also apply.

3.13.2 certificate of conformance (CoC)document that confirms conformance to relevant specifications or regulations. NOTE This is sometimes referred to as a certificate of compliance or declaration of compliance.

3.3 cleaning removal of solvents, grease or lubricant, ink residues or other objectionable matter.

3.4 contaminant any biological or chemical agent, foreign matter or other substance not intentionally added to the product that may compromise its safety or suitability [Adapted from Codex Alimentarius, 2.3]. NOTE Measures for prevention of malicious contamination are outside the scope of this PAS. For further information and guidance on approaches to the protection of food businesses from all forms of malicious attack, see PAS 96, Defending food and drink which will provide guidance for the deterrence, detection and defeat of ideologically motivated and other forms of malicious attack on food and drink and their supply arrangements.

3.5 contamination introduction or occurrence of a contaminant in the product or the production environment [Adapted from Codex Alimentarius, 2.3]. NOTE In the context of this PAS, “contamination” may also refer to the introduction of non-intentionally added substances (NIAS).

3.6 establishment any building or area in which raw materials, intermediate materials, chemicals or finished food packaging are handled, and the surroundings under the control of the same management [Adapted from Codex Alimentarius, 2.3].

3.7 finished food packaging physical final output of any kind of production process that takes place in food packaging manufacturing organizations.

3.8 food packaging any product to be used for containment, protection, handling, delivery, storage, transport and presentation of food. NOTE Food packaging may have direct, indirect and no contact with the food. Direct food contact surfaces or materials are in contact (i.e. physically touching the food or in contact with the headspace) or will be in contact with the food during normal use of the food packaging.

Indirect food contact surfaces or materials are not in direct contact with the food during normal use of the food packaging, but there is the possibility for substances to transfer into the food. Non-contact surfaces or materials are not in direct contact with the food during normal use of the food packaging, and there is no possibility for substances to transfer into the food.

3.9 food packaging withdrawal removal of nonconforming food packaging from the market, trade warehouses, distribution centers or customer operations and warehouses because it does not meet specified food safety standards or requirements.

3.10 intermediate material physical output of part of the production process that still requires further processing to create finished food packaging.

NOTE For example, a plastic powder, granules or flakes (including “master batch”), ink, coating, adhesive, pre-polymer, any semi-finished material and article such as a film, sheet or laminate requiring further processing/reformulation steps to become a finished material or article. In short, this is any product that is not a basic chemical and not yet a finished material or article, and includes part-processed, semi-converted and converted materials.

3.11 label printed matter that is, or is intended to be, part of the finished package conveying specific information about the contents of the package, the food ingredients and any storage and preparation requirements.

NOTE This includes the package itself, printed matter that is, or is intended to be, attached to the package or a sticker used for over-labeling.

3.12 migration transfer of substances from an external source (e.g. packaging material, environment) to food.

NOTE Transfer of substances can take place by migration through the substrate, by set-off to the reverse side and subsequent migration into food, or by gas phase transfer.

3.13 non-intentionally added substance (NIAS) impurity in the materials used in, or a decomposition or reaction product formed during, the production process.

3.14 packing materials materials used to hold and protect food packaging during shipping, transport and storage.

3.15 set-off transfer of substances from one side of a material or product to the other side through direct contact between the sides caused by the stacking or reeling of the material or product .

3.16 specification detailed description of the properties and requirements of a material or product, in particular its technical and specific suitability .

3.17 waste any substance or object that the food packaging manufacturing organization discards or intends or is required to discard.