Danielle Tan
Chief Operating Officer
Learn how FSSC 22000 Version 7 changes food packaging management, with practical steps to stay safe, compliant, and audit-ready.
Quick summary: FSSC 22000 Version 7 shifts packaging from a routine purchasing task to a managed food safety control, one that protects product integrity, legal compliance, and consumers. This guide walks through exactly what changed and the practical steps to keep your packaging safe, compliant, and audit-ready.
FSSC 22000 Version 7 changes the way you manage packaging by placing greater emphasis on risk-based thinking, stronger control of externally provided products and services, food safety culture, equipment management, and compliance with food contact requirements.
Packaging is now treated as a critical element of food safety that can directly affect product integrity, legal compliance, and consumer protection, well beyond its role as a purchasing activity. That means food manufacturers should strengthen their packaging risk assessments, supplier management, verification activities, and ongoing monitoring so packaging stays suitable throughout its intended use.
Why Packaging Deserves More Attention
Packaging does much more than contain food. It protects products from contamination, preserves shelf life, prevents physical damage, provides legally required information, and helps maintain product quality throughout distribution.
If packaging fails, the consequences can be significant:
• Chemical migration into food
• Physical contamination from damaged packaging
• Incorrect or misleading labels
• Loss of product shelf life
• Customer complaints
• Product recalls
• Regulatory non-compliance
As food products become more complex and supply chains more global, packaging benefits from active, risk-based management that goes beyond supplier certificates or historical experience.
What Has Changed in FSSC 22000 Version 7?
Packaging has always been part of food safety management, and Version 7 reinforces several areas that directly influence packaging management. Here is a quick summary before the detail:
| Area | What It Means for Packaging | Your Action |
| Risk-based thinking | Packaging carries different levels of risk | Match approval and checks to each material’s risk level |
| External providers | Suppliers should deliver safe, compliant packaging | Approve on food safety evidence alongside price and delivery |
| Verification | Controls should be proven effective | Inspect, check specifications, and verify seals and labels |
| Food safety culture | Human factors cause many packaging errors | Train staff to treat packaging as a safety control |
| Change management | Every change can affect safety | Review changes formally before they go live |
Version 7 also adds packaging design considerations, based on the Save Food Packaging principles developed by the Australasian Institute of Packaging (AIP) and globalised by the World Packaging Organization (WPO), for organizations involved in designing primary packaging and packaging materials, with the aim of reducing food loss and waste.
The following sections explain each area in more detail and how to apply it day to day.
1. Stronger Risk-Based Thinking
Organizations are expected to determine risks and opportunities throughout their food safety management system, and that includes the packaging materials used in production. When approving packaging suppliers, companies should weigh risk factors such as:
• Type of food contact
• Intended product use
• Packaging material (plastic, glass, metal, paper, laminates)
• Chemical migration potential
• Supplier performance history
• Country of origin
• Regulatory compliance
• Previous incidents or recalls
Higher-risk packaging should receive more stringent approval and verification activities than lower-risk materials.
2. Greater Focus on External Providers
Most food manufacturers buy packaging from external suppliers, and Version 7 reinforces the importance of making sure those suppliers consistently provide safe, compliant packaging.
Supplier approval should extend beyond price and delivery performance. A robust supplier management programme should include:
• Supplier evaluation and approval
• Food safety certifications where applicable
• Food contact compliance documentation
• Declaration of Compliance (DoC)
• Migration test reports when required
• Specifications and technical data sheets
• Periodic supplier performance reviews
• Risk-based supplier audits where necessary
Together these give you far more confidence that packaging is fit for its intended application.
3. Better Verification Activities
Version 7 encourages organizations to verify that planned controls actually work, and for packaging that verification should continue well after supplier approval. Examples include:
• Incoming packaging inspection
• Verification against approved specifications
• Label artwork approval
• Packaging dimensional checks
• Seal integrity verification
• Packaging performance during production
• Review of customer complaints related to packaging
• Periodic review of supplier documentation
These checks give you evidence that packaging controls keep performing as intended.
4. Increased Focus on Food Safety Culture
Strengthening food safety culture is one of the biggest themes in Version 7, and packaging errors tend to come from human factors more often than technical failure. Common examples:
• Wrong packaging issued to production
• Incorrect labels applied
• Mixing different packaging versions
• Damaged packaging accepted into production
• Unapproved substitute packaging used during shortages
Employees should understand that packaging is a food safety control, not simply a production material. Training should cover:
• Packaging identification
• Storage requirements
• Handling practices
• Label verification
• Reporting damaged materials
• Traceability requirements
When people understand why packaging matters, mistakes become less frequent.
5. Stronger Change Management
Packaging changes happen regularly: a new supplier, a new packaging material, a new print design, a different adhesive or ink, a product launch, or a sustainability initiative. Any of these has the potential to affect food safety.
A structured change management process should ask whether a change calls for:
• Updated specifications
• Additional migration testing
• Shelf-life verification
• Customer approval
• Regulatory review
• Risk assessment updates
• Validation before implementation
Handling changes this way prevents unintended food safety issues after changes are introduced.
Facing the Version 7 transition? A short packaging review now surfaces the gaps auditors look for before the deadline. Book a 1-on-1 consultation with Nexus Consultancy.
Practical Actions for Food Manufacturers
To align your packaging management with FSSC 22000 Version 7, consider reviewing the following:
• Conduct a packaging-specific risk assessment for all food contact materials.
• Review packaging specifications to ensure they remain current and complete.
• Verify that supplier documentation is valid and up to date.
• Define risk-based verification activities for incoming packaging.
• Include packaging-related risks in management review discussions.
• Ensure packaging changes follow formal change management procedures.
• Train employees on packaging handling, identification, and verification.
• Monitor packaging complaints and analyse trends for continual improvement.
Together these show that packaging risks are identified, controlled, and regularly reviewed.
Common Questions About FSSC 22000 Version 7 and Packaging
1. Does FSSC 22000 Version 7 introduce new packaging requirements?
A: Yes, one. Version 7 adds a packaging design requirement for companies that design primary packaging or packaging materials. Beyond that, it has no standalone packaging clause; it strengthens existing expectations around risk-based thinking, supplier control, verification, food safety culture, and change management.
2. Is a Declaration of Compliance (DoC) enough to approve packaging?
A: No, a DoC alone is not enough. It’s a useful supplier document, but before approving packaging you should also check the specifications, how it touches the food, regulatory compliance, the supplier’s track record, and, for higher-risk packaging, migration test reports.
3. Should packaging be included in the HACCP study?
A: Packaging itself is typically managed as a prerequisite programme (PRP) rather than a hazard control measure within the HACCP plan. Even so, hazards linked to packaging and its materials, such as chemical migration, physical contamination, or incorrect labels, should be considered during hazard analysis, with controls established where necessary.
4. How often should packaging suppliers be re-evaluated?
A: There is no fixed interval in FSSC 22000 Version 7. Base re-evaluation on risk and supplier performance, taking into account complaint trends, changes in materials or manufacturing processes, certification status, audit results, and regulatory updates.
5. What evidence will an auditor typically expect during an FSSC 22000 audit?
A: Auditors commonly look for documented packaging specifications, approved supplier records, food contact compliance documents, risk assessments, incoming inspection records, verification activities, change management records, training evidence, and records demonstrating continual monitoring and improvement of packaging controls.
Final Thoughts
FSSC 22000 Version 7 encourages organizations to treat packaging as an integral part of the food safety management system alongside its role as a purchased material. With stronger risk assessments, closer supplier oversight, effective verification, structured change management, and a positive food safety culture, manufacturers can better protect their products, consumers, and brands.
Ultimately, effective packaging management supports your certification while making sure every package reaching the customer performs exactly as intended, from production through to consumption.
How Nexus Consultancy Can Help
Nexus Consultancy helps food manufacturers turn packaging into a managed, audit-ready part of their food safety system:
• FSSC 22000, ISO 22000, BRCGS & HACCP Consultancy: build and maintain your packaging risk assessments, supplier controls, and verification within a certified food safety management system.
• Food Safety Training: strengthen your team’s skills in packaging controls, food contact compliance, and internal auditing.
• Business Digitalization: move supplier documents, specifications, and verification records off spreadsheets into one centralised, reminder-driven system.
Book a consultation to review your packaging controls and spot compliance gaps before your next audit.
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