Food Packaging Compliance: What's Required
Food packaging compliance is one of the most scrutinized areas in contract packing. HACCP certification, food contact material safety, allergen management and temperature control are all mandatory requirements that your co-packer needs to get right every time.
This guide covers the core compliance requirements for food packaging in Australia and the broader region. We explain what HACCP actually requires, how food contact materials are regulated, what allergen management looks like in practice and how to evaluate whether a co-packer can safely handle your food products.
At CleverPak, food and beverage packing is one of our largest service categories. Our food-grade facilities hold HACCP certification and operate under strict food safety protocols. The requirements are detailed and the penalties for non-compliance are serious, so understanding what's involved helps you ask the right questions before choosing a partner.
HACCP Certification Explained
HACCP (Hazard Analysis and Critical Control Points) is the internationally recognized food safety management system. In Australia, HACCP-based food safety programs are required under the Food Standards Code (Standard 3.2.1) for food businesses.
HACCP works by identifying potential hazards (biological, chemical and physical) at every stage of food handling and establishing controls to prevent them. For contract packing, this covers receiving raw materials, storage conditions, the packing process itself, labeling and dispatch.
A HACCP-certified facility maintains documented procedures across seven core principles: hazard analysis, critical control point identification, critical limits, monitoring procedures, corrective actions, verification procedures and record-keeping.
For co-packing specifically, HACCP certification means the facility has been audited and verified to handle food products safely. It's not a one-time certification. HACCP requires ongoing monitoring, regular internal audits and periodic third-party recertification (typically annually). Your co-packer should be able to provide their current HACCP certificate and audit reports on request.
Food Contact Material Requirements
Any packaging material that directly touches food must comply with food contact material (FCM) regulations. In Australia, FSANZ Standard 1.6.1 requires that packaging materials do not transfer substances to food in quantities that could harm health or change the food's composition, taste or odor.
Australia doesn't maintain a positive list of approved food contact materials like the EU does. Instead, the standard applies a general safety requirement and references international standards (including EU Regulation 1935/2004 and FDA CFR Title 21) as accepted frameworks for demonstrating compliance.
In practice, this means your co-packer needs to verify that all packaging materials used in food packing have appropriate food contact compliance documentation from the material supplier. This includes migration testing results for plastics, certification of food-grade inks and adhesives, and documentation for any coatings or treatments applied to packaging.
If your co-packer sources packaging materials on your behalf, they should provide food contact compliance certificates for every material. If you supply the materials yourself, provide these certificates to the co-packer as part of the project setup.
Allergen Management
Allergen management in food packing is governed by FSANZ Standard 1.2.3, which requires mandatory declaration of allergens from a defined list: peanuts, tree nuts, milk, eggs, fish, crustaceans, soybeans, sesame, wheat, lupin and their products.
For contract packing, allergen management goes beyond label accuracy. Your co-packer needs operational controls to prevent cross-contamination during the packing process. This includes dedicated packing areas or thorough cleaning between allergen-containing and allergen-free products, staff training on allergen handling protocols and documented changeover procedures.
Precautionary allergen labeling (such as "may contain traces of...") is voluntary but increasingly important. FSANZ has developed guidance (VITAL 3.0) for assessing when precautionary statements are appropriate, based on quantitative risk assessment rather than blanket "may contain" statements.
Ask your co-packer specifically: how do they manage allergen changeovers? What cleaning validation do they perform? Can they demonstrate that cross-contamination risks are controlled? A co-packer that can't answer these questions in detail isn't ready to handle food products safely.
Cold Chain and Temperature Control
Some food products require temperature-controlled storage and packing environments. Chocolate, dairy-based products, temperature-sensitive supplements and anything with cold chain requirements need facilities with appropriate climate control.
Food Standards Code Standard 3.2.2 requires food businesses to store and handle potentially hazardous foods at safe temperatures: at or below 5°C for cold storage and at or above 60°C for hot holding. For contract packing, this means the facility needs temperature monitoring systems, documented temperature logs and alarm systems for deviations.
Even products that don't require refrigeration often have temperature limits. Chocolate starts to bloom above 25°C. Gummy supplements can melt and fuse together in hot warehouse conditions. Liquid products in glass can crack if exposed to extreme temperature swings.
When evaluating a co-packer for temperature-sensitive products, ask about their facility's temperature range, monitoring systems and backup procedures for equipment failures. CleverPak's food-grade facilities maintain documented temperature controls with digital monitoring and automated alerts for deviations outside acceptable ranges.
Choosing a Food-Compliant Co-Packer
Selecting a co-packer for food products requires verification beyond standard due diligence. Here's what to confirm before engaging any food packing partner.
Start with certifications. HACCP certification is the minimum for food packing. Ask for the current certificate and most recent audit report. Some retailers and food service customers also require SQF (Safe Quality Food) or BRCGS (British Retail Consortium Global Standards) certification, so check your customers' requirements before selecting a facility.
Verify their allergen management protocols. Ask for their allergen management plan, changeover procedures and cleaning validation records. If your products are allergen-free and you need guarantees against cross-contamination, the facility needs dedicated allergen-free zones or rigorous changeover procedures.
Check their temperature control capabilities if your products are temperature-sensitive. Digital monitoring, documented temperature logs and alarm systems should be standard.
Review their [traceability system](/services/labeling-tagging/barcodes-tracking). Every food packing run should link to a batch record with material lot numbers, production dates, quality checks and worker assignments. One-up-one-down traceability (knowing where materials came from and where finished goods went) is the minimum standard.
Frequently Asked Questions
Is HACCP certification mandatory for food co-packing?
In Australia, food businesses are required to have a food safety program based on HACCP principles under FSANZ Standard 3.2.1. While the requirement technically applies to the food business (the brand), your co-packer should hold their own HACCP certification to demonstrate they can safely handle food products. Most retailers and food service companies require HACCP certification from all suppliers in the chain, including co-packers.
What happens if allergen cross-contamination occurs during packing?
Allergen cross-contamination can trigger a product recall, which typically costs between AUD $10,000 and $500,000+ depending on the scale. Beyond financial cost, recalls damage brand trust and retailer relationships. In serious cases, FSANZ can issue public warnings and require a market-wide withdrawal. Prevention through proper facility design, cleaning procedures and allergen management plans is far cheaper than dealing with a recall.
Can the same facility pack allergen-free and allergen-containing products?
Yes, with proper controls. This requires documented changeover procedures, validated cleaning protocols between production runs and physical segregation of allergen-containing materials. Some facilities maintain dedicated allergen-free zones for products that need guaranteed absence of specific allergens. Ask your co-packer for their changeover validation data and allergen management plan.
Does CleverPak handle food-grade packing?
Yes. CleverPak operates HACCP-certified facilities for food and beverage contract packing. Our food-grade operations include temperature-controlled environments, allergen management protocols, food contact material verification and full batch traceability through CleverPak Connect. We pack across categories including confectionery, dry goods, supplements, beverages and specialty food products.
What documentation should I get from a food co-packer?
At minimum: current HACCP certificate, most recent audit report, allergen management plan, food contact material compliance certificates for all packaging materials used, temperature monitoring logs (for temperature-sensitive products) and batch production records for every run. A good co-packer provides all of this proactively. If you have to chase for documentation, that's a warning sign.