A supplier change is a technical change until equivalence has been demonstrated. Commercial descriptions such as “500 ml PET bottle”, “28 mm cap” or “standard label roll” do not define tolerances, sealing features, materials, line behaviour or evidence scope. Control the change through documents, samples, trials and an approved release record.
Use a staged change route
| Stage | Evidence | Release decision |
|---|---|---|
| Define current reference | Approved drawing, samples, material, evidence, line settings and known tolerances | Baseline agreed |
| Document comparison | Candidate drawing, declarations, manufacturing site and change-notification terms | Gaps identified |
| Sample inspection | Dimensions, appearance, fit, seal features and lot variation | Candidate accepted for trial |
| Production and pack trial | Feeding, filling, closing, labelling, sealing, coding and distribution checks | Acceptance criteria met or actions raised |
| Controlled release | Approved code, documents, samples, settings and monitoring plan | Purchasing and production authorised |
What counts as a packaging specification change?
Any change that can alter identity, performance, compliance, evidence or line behaviour should enter change control. Examples include supplier, manufacturing site, resin or paper grade, recycled-content route, colour, layer, coating, adhesive, dimensions, tolerances, neck finish, liner, tamper feature, roll direction or artwork.
A commercial product code remaining the same does not prove that the technical specification is unchanged.
Can a new supplier be approved by matching the old product description?
No. A matching description is only a starting point. Compare controlled drawings and tolerances, materials, component weights, sealing features, regulatory declarations, environmental evidence and production samples. Check whether the new supplier uses a different manufacturing site or process.
Equivalence should be defined by the acceptance criteria that matter to the actual product and line, not by appearance alone.
Which documents and samples should be compared?
Compare the current and candidate drawings, specifications, material or layer declarations, compliance documents, evidence for any claim, artwork interfaces and change-notification terms. Inspect several samples across the candidate lot and retain approved references.
Where closures, labels or pouches are involved, include the mating component and relevant application equipment in the sample review.
Which line trials should be repeated after a packaging change?
Repeat every test that could be affected by the changed property. This may include feeding, conveying, filling, sealing, torque, leak checks, tamper evidence, labelling, coding, shrink, case packing and distribution. A colour change may also affect optical sensors or sorting evidence.
Use the same acceptance criteria as the original approval where they remain appropriate and record any changed settings.
How should an approved packaging change be recorded?
Issue a controlled specification and release record linked to the new supplier code, drawings, declarations, approved samples, trial results and effective date. Update purchasing, incoming inspection, line recipes, artwork references and EPR or environmental records where affected.
Define the first-production monitoring plan and the events that will trigger another review.
Do not release the change until
- The candidate and current specification have been compared line by line.
- Evidence gaps and limitations have an owner and resolution.
- Representative samples have passed the agreed line and pack tests.
- Purchasing and production reference the approved new code.
- Claim, EPR and regulatory records have been updated where necessary.
Authoritative references
These sources are starting points for the applicable UK requirement or disposal context. The current version, territorial scope and exact packaging application should be checked when a decision is approved.