Danielle Tan
Chief Operating Officer
A practical guide for food manufacturers to the seven packaging nonconformities most often raised in FSSC 22000 audits, with prevention steps for each.
Quick summary: Most packaging findings in FSSC 22000 audits come down to seven recurring gaps in how packaging is selected, verified, approved and controlled. Tightening those controls is what lowers the risk of nonconformities at certification and surveillance audits.
The most common packaging nonconformities found during FSSC 22000 audits include inadequate packaging specifications, uncontrolled packaging changes, incorrect or unverified artwork, weak supplier control, insufficient packaging validation, poor traceability, and inadequate storage and handling of packaging materials. These issues can compromise food safety, product quality, regulatory compliance and consumer confidence. By understanding these recurring audit findings, food manufacturers can strengthen their packaging management system and reduce the risk of nonconformities during certification and surveillance audits.
Packaging is no longer viewed as merely a means of containing a product. Under FSSC 22000 (Food Safety System Certification 22000), packaging is treated as an important part of the food safety management system because it directly affects product protection, contamination prevention, traceability and legal compliance. During audits, certification bodies often identify gaps in packaging management that trace back to the processes used to select, verify, approve and control packaging materials, while the packaging itself remains sound.
A nonconformity is any point where an FSSC 22000 requirement is not met. Below are seven that appear often during audits, with practical ways to prevent each one. For the wider context on how the latest revision reshapes packaging expectations, see our guide on how FSSC 22000 Version 7 changes the way you manage packaging.
At a Glance: The Seven Packaging Nonconformities
| # | Nonconformity | What auditors look for | How to prevent it |
|---|---|---|---|
| 1 | Incomplete packaging specifications | Missing technical, food-safety or regulatory requirements | Maintain complete specifications covering composition, barrier, storage, shelf life and acceptance criteria |
| 2 | Uncontrolled packaging changes | Changes adopted without risk assessment or approval | Route every change through formal change management before implementation |
| 3 | Unverified artwork | Missing allergen or ingredient details, barcode or version errors | Apply a documented review, approval and independent verification step |
| 4 | Insufficient validation | Reliance on supplier claims without in-house evidence | Validate packaging under actual production, storage and transport conditions |
| 5 | Weak supplier control | Suppliers approved without evaluation or ongoing monitoring | Qualify, monitor and periodically reassess packaging suppliers |
| 6 | Poor traceability | Packaging lots not linked to finished products | Record batch numbers and link packaging to production runs |
| 7 | Improper storage and handling | Packaging exposed to floor contact, dust, pests or chemicals | Store off the floor, protected, rotated and away from chemicals |
1. Incomplete Packaging Specifications
One of the most common findings is the absence of comprehensive packaging specifications. Some organisations only retain basic product information such as dimensions or colour, while omitting critical technical requirements.
A complete packaging specification should include:
• Food-contact suitability
• Material composition
• Barrier properties
• Storage conditions
• Shelf-life compatibility
• Regulatory requirements
• Printing specifications
• Acceptance criteria
Without detailed specifications, organisations cannot consistently verify whether incoming packaging materials meet their requirements.
2. Packaging Changes Without Formal Change Control
Packaging suppliers occasionally modify raw materials, adhesives, printing methods or manufacturing processes. If these changes are implemented without evaluation, they may introduce food safety or quality risks.
Auditors frequently identify situations where packaging changes were adopted without documented risk assessment, validation or approval.
Every packaging change, however minor it appears, should pass through a formal change management process involving quality assurance, technical and production personnel before implementation.
3. Unverified Packaging Artwork
Incorrect artwork continues to be one of the leading contributors to packaging-related food recalls. Common audit findings include missing allergen declarations, incorrect ingredient lists, outdated nutritional information, incorrect product names, missing regulatory statements and barcode errors.
FSSC 22000 expects organisations to have effective controls for reviewing, approving and verifying packaging artwork before production begins. Independent verification significantly reduces the likelihood of human error.
4. Inadequate Packaging Validation
Many organisations rely solely on supplier information when introducing new packaging materials. However, certification auditors often expect evidence that packaging has been validated under actual operating conditions.
Validation should demonstrate that the packaging:
• Protects product quality throughout shelf life
• Performs consistently on production equipment
• Maintains seal integrity
• Withstands transportation and storage conditions
• Supports intended food safety objectives
Without documented validation, it is difficult to demonstrate confidence that the packaging is fit for purpose.
Want a clear picture of where your packaging controls stand before an audit? A short gap assessment shows where the risks sit ahead of certification or surveillance. 👉 Contact us to arrange a packaging gap assessment
5. Weak Supplier Approval and Monitoring
Packaging suppliers are an extension of your food safety management system. Audit findings commonly include suppliers approved without technical evaluation, expired supplier assessments, missing food-contact compliance documentation, a lack of supplier performance monitoring, and no review following recurring quality issues.
Effective supplier management should include initial qualification, periodic performance reviews, change notifications and verification of regulatory compliance.
6. Poor Packaging Traceability
Traceability applies to packaging materials as well as ingredients. Auditors may identify issues such as missing packaging batch numbers, packaging lots not linked to finished products, incomplete receiving records, poor inventory identification, and difficulty identifying affected products during mock recalls.
Strong packaging traceability enables organisations to respond quickly during product withdrawals or recalls while minimising unnecessary product disposal.
7. Improper Storage and Handling of Packaging Materials
Packaging materials can become contaminated before they ever reach the production line.
Common findings include:
• Packaging stored directly on the floor
• Damaged packaging used in production
• Open packaging exposed to dust or pests
• Packaging stored near chemicals or cleaning agents
• Poor stock rotation practices
• Inadequate environmental controls for sensitive materials
Proper storage conditions help maintain packaging integrity and prevent contamination before use.
Packaging Management Is More Than a Purchasing Function
Many organisations focus on selecting attractive packaging or negotiating competitive pricing. However, FSSC 22000 takes a broader perspective. Packaging should be managed through the same risk-based approach applied to ingredients, equipment and production processes.
An effective packaging management programme includes documented specifications, supplier approval, incoming verification, validation, artwork control, traceability, change management and ongoing monitoring. When these elements work together, packaging becomes a strong barrier against food safety risks.
Practical steps to stay audit-ready
• Maintain complete, current specifications for every packaging material
• Approve suppliers on evidence, then monitor and reassess them
• Verify incoming materials against the specification
• Validate new or changed packaging under real operating conditions
• Review and independently verify artwork before production
• Link packaging batches to finished products for full traceability
• Route every change through formal change management
• Store packaging off the floor, protected and correctly rotated
By proactively reviewing these seven common audit findings, organisations can improve compliance, strengthen product protection and approach FSSC 22000 audits with greater confidence.
Common Questions About Packaging in FSSC 22000 Audits
How Nexus Consultancy Can Help
Nexus Consultancy helps food manufacturers build packaging management systems that hold up under certification and surveillance audits. Support includes gap assessments against FSSC 22000 requirements, packaging specification and supplier approval frameworks, artwork and change control procedures, validation and traceability guidance, and internal auditor and awareness training for your team.
Book a consultation to review your packaging management system and spot compliance gaps before your next audit.
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