Running a safe mill is one half of the job; the other is meeting the rules that attach to paper products themselves and to the packaging you put on the market. Which apply depends on what you make. Work through the sections that fit your products. The Office for Product Safety and Standards (OPSS) and local Trading Standards enforce general product safety; food-contact materials are enforced by local authorities and Trading Standards, with the Food Standards Agency (and Food Standards Scotland) overseeing the policy; and the packaging producer- responsibility scheme is run by the environmental regulators and the scheme administrator.
A. Meet general product safety for consumer goods
Paper and board consumer goods that fall outside a specific regime — stationery, tissue and household paper, paper craft and decorative goods — must be safe under the General Product Safety Regulations 2005, the residual catch-all enforced by OPSS and local Trading Standards. In Northern Ireland the EU General Product Safety Regulation applies instead under the Windsor Framework.
B. Meet the food-contact materials rules
If you make paper or board intended to come into contact with food — cartons, wrapping, bags, cups, plates, baking papers and food packaging board — it must meet the food-contact materials rules. The materials must not transfer their constituents to food in amounts that could harm health or change the food, you must manufacture to good manufacturing practice, and you must be able to support the product with a declaration of compliance and the supporting documentation. The framework comes from assimilated EU law — the framework Regulation on food-contact materials and the good-manufacturing-practice Regulation — together with the Materials and Articles in Contact with Food Regulations in each UK nation, enforced by local authorities and Trading Standards. The Food Standards Agency (and Food Standards Scotland) oversee the policy. Build compliance and your declaration of compliance into your specification.
C. Meet your packaging producer responsibility duties
If you make or supply packaging — including the paper and board packaging you produce, and any packaging you use to ship your own products — you are likely to be a producer under the extended producer responsibility (EPR) scheme for packaging. Depending on your size and the packaging you handle, you must collect packaging data, report it, register, and pay the producer fees that fund the collection and recycling of packaging waste. Check whether you are an obligated producer and meet your data, reporting and fee duties.
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1. Check general product safety for consumer goods
Make sure paper and board consumer goods outside a specific regime are safe under the General Product Safety Regulations 2005.
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2. Meet the food-contact materials rules for food packaging
If you make food-contact paper or board, manufacture to good manufacturing practice, keep within the migration and composition rules, and support each product with a declaration of compliance.
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3. Meet your packaging producer responsibility duties
Check whether you are an obligated producer under packaging EPR, then collect and report your packaging data, register, and pay the producer fees.
What to do next
With your safe-mill spine, your environmental and water duties and your product duties in place, confirm the whole picture with the paper manufacturer compliance checklist. Start from the router if you are not sure which guides apply to you.
Official sources
Authoritative product-safety, food-contact and packaging guidance.