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Container Coding Requirements for Low Acid Canned Foods

The US FDA requires Low Acid Canned Foods to be marked with an identifying code.     The Regulations state the following:

21 CFR section 113.60(c)  Coding.  Each hermetically sealed container of low-acid processed food shall be marked with an identifying code that shall be permanently visible to the naked eye.  When the container does not permit the code to be embossed or inked, the label may be legibly perforated or otherwise marked, if the label is securely affixed to the product container.  The required identification shall identify in code the establishment where packed, the product contained therein, the year packed, the day packed, and the period during which packed.  The packing period code shall be changed with sufficient frequency to enable ready identification of lots during their sale and distribution.  Codes may be changed on the basis of one of the following: intervals of 4 to 5 hours; personnel shift changes; or batches, as long as the containers that constitute the batch do not extend over a period of more than one personnel shift. 

FDA requires that containers be properly coded in the event a firm has the need to recall their product due to a safety or quality problem.  In that case, the container code is used to identify the affected product.   Codes are also useful for inventory control and tracking of shipments.

In summary, the FDA requirements are:

  1. The code shall be permanently visible to the naked eye
  2. The code shall identify the following:
    • establishment where packed
    • product contained therein
    • year packed
    • day packed
    • period during which packed.( this refers to the shift, batch or interval in which the product was packed.)

 A further explanation of this is as follows:

  • Permanently visible to the naked eye -- this can be accomplished by ink jetting or embossing the code onto the container.  Ink jet markings can be placed at any location on the container as long as it is readable (this is normally done on the top or bottom of a container).
  • Establishment where packed -- you can choose a code to identify what plant the product was packed, as long as this code is used consistently.  
  • Product contained therein -- you can choose either an alpha or numeric representation as the code for this identification factor.  An example of this would be to code each product type packed with a different letter or number.  For example, Mushrooms Pieces & Stems in Brine could be number “1” or designated by letters “MPSB”.  The coding system used must be consistent and documented to keep track of what each code identifies.
  • Year packed -- this can be easily identified by using the numeric representation of the year.  The year 1999 can be referred to as “99” or simply “9”.  
  • Day packed -- this can be easily identified by using the numeric representation of the date in one of two ways. You can take the date March 11 and identify it as “0311”  03 for March and 11 for the 11th day of the month.  You can also use the Julian date system, which is based on the number of days in a year.  For example; January 1 is represented as “001” and December 31 is represented as “365” in a non-leap year.  This would make the numeric representation of  March 11, “071”, because it is the 71st day of the year (during a leap year).
  • Period during which packed -- (if you use shifts in the factory) this can be an alpha or numeric representation of the shift, batch or interval in which the product is packed.  The code must not continue unchanged between shifts.  We recommend the code at least include the shift in which the product was packed.  You can use the numeric representation of the shift as “1”, “2” ect. to represent the first shift, second shift, ect.

NOTE:  The SID# for the product is NOT required to be included in the code.  Nor is the FCE# or FFR#.  Neither of these registration or filing numbers are required to be listed in the container code. 

The code must be "Permanently Visible", typically either embossed or ink jetted onto each container (can, pouch, jar, etc.).  

Using the examples listed above, we will code the following product:

  • Mushrooms, Pieces & Stems in brine (coded as MPSB)
  • packed at the Factory ABC (coded as ABC)
  • on February 1, 1999 (coded as 99032; 99 for the year, 032 day packed)
  • during the first shift of production.(coded as 1)

The order in which the code is displayed is not a requirement, however, it must be consistent.

The code on this product should be displayed as follows:

 ABC
MPSB
99032-1

If you have any questions, please contact TechniCAL

Scott Cabes
President- TechniCAL
scabes@tcal.com

 

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