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Brazil Publishes Draft Resolution on GMPs for Food Packaging

Brazil's National Health Surveillance Agency (Agência Nacional de Vigilância Sanitária (ANVISA)) recently released a draft technical resolution addressing Good Manufacturing Practices (GMPs) for manufacturers that produce packaging intended for direct contact with food. (It is not intended to cover the manufacture of materials that must be further processed to become packaging articles.) The draft resolution (currently available only in Portuguese) describes GMP measures that should be implemented to ensure that food packaging is made under conditions that minimize the possibility of contamination, which may result in the adulteration of food.

The resolution would require that packaging producers design and implement a GMP manual. A "GMP Checklist" is also attached as Annex 1 to the draft resolution, which could potentially be used by ANVISA inspectors, although the resolution is otherwise silent with regard to inspections.

ANVISA is currently accepting comments on the resolution. Once finalized, food packaging manufacturers will have 18 months from the date of final publication to come into compliance with the applicable requirements. Article 64 indicates that failure to comply with the resolution would be a sanitary infraction, potentially resulting in civil, administrative, and/or criminal penalties.