📌 Key Takeaways
Certificate validity determines whether a kraft paper supplier makes your shortlist or gets filtered out—expired FSC certificates halt production, ISO scope mismatches trigger re-qualifications, and missing food-contact proof exposes brands to regulatory risk.
- Registry Verification Takes 10 Minutes: Check fsc.org and PEFC at pefc.org to confirm “Active” status, then match the certificate scope to the exact grades you’re buying—a scope covering “unbleached kraft” doesn’t authorize bleached liner claims.
- Entity Mismatches Kill Certified Claims: The FSC or PEFC license code on your invoice must belong to the exact legal entity issuing that invoice—if the certificate belongs to “ABC Paper Mills Ltd” but invoices come from “ABC Trading International,” the claim won’t survive audit.
- ISO Scope Language Predicts Qualification Success: Vague phrases like “manufacture of paper products” provide no assurance; specific product names (kraft linerboard, MG kraft, sack kraft) with GSM ranges and test method references (TAPPI T 410, ISO 2758) prevent disputes over whether delivered material meets spec.
- Food-Contact Proof Requires Two Documents: A Declaration of Compliance naming regulatory basis (FDA 21 CFR Part 176 or EU 1935/2004) plus migration test reports from an ISO 17025-accredited lab dated within two to three years—the DoC is the claim, the test data is the proof.
- 30-Minute Workflow Eliminates Back-and-Forth: Request evidence pack, validate registries, check scope alignment, map to specifications, then log the decision—suppliers who provide direct registry links and certificate-to-product matrices speed approvals and reduce qualification cycles.
Certificate integrity creates defensible proof that you can legally sell products made from that paper into regulated markets.
Procurement managers sourcing kraft paper, kraft linerboard, or sack kraft for food packaging applications will find a systematic verification process here, preparing them for the detailed certification frameworks and compliance protocols that follow.
Certification claims on a supplier’s website look convincing until you dig deeper. The FSC logo is there, the ISO badges are displayed prominently, and the sales team assures you everything is compliant. Then, three weeks into due diligence, you discover the FSC certificate expired six months ago, the ISO 9001 scope doesn’t actually cover the kraft liner grades you’re buying, or the food-contact declaration lacks the migration test data your legal team requires.
For procurement managers sourcing kraft paper, kraft linerboard, or sack kraft for food packaging applications, certificate validity isn’t just a box-ticking exercise—it’s a gating criterion that determines whether a mill makes your shortlist or gets filtered out. A withdrawn FSC certificate can halt production. An ISO scope mismatch can trigger costly re-qualifications. Missing food-contact proof can expose your brand to regulatory risk.
This guide provides a practical, step-by-step verification process that takes 30 to 45 minutes per supplier. You’ll learn exactly which documents to request, how to validate them against official registries, and which red flags indicate a supplier isn’t audit-ready. For mills and exporters, you’ll see how to organize evidence in a format that speeds approvals and reduces back-and-forth requests.
Why Certification Integrity Matters in Kraft Paper Sourcing
Kraft paper manufacturer certifications are third-party validations that a mill’s processes, materials, and quality systems meet defined international standards. The three primary certification families in kraft paper procurement are forestry chain-of-custody (FSC and PEFC), quality and environmental management systems (ISO 9001 and ISO 14001), and food safety management (ISO 22000 or FSSC 22000).
Certification integrity reduces compliance risk. It does this by ensuring the mill’s documented processes and materials are traceable and valid at audit time, preventing the downstream disruptions that occur when a buyer discovers—mid-contract—that the claimed certification doesn’t cover the specific product grades or production lines they’re purchasing from.
Think of certificate verification like checking that a driver’s license is current and covers the vehicle class they’re operating. The license might be real, but if it expired last year or only permits passenger cars when they’re driving a commercial truck, it doesn’t provide the legal protection you assumed it did. Similarly, an FSC certificate that’s valid but scoped only for unbleached kraft doesn’t cover the bleached grades your packaging spec requires.
Here’s the practical application: a corrugator qualifying a new kraft liner supplier for a multinational FMCG client will face contractual penalties if the mill’s FSC chain-of-custody claim later fails a downstream audit. The corrugator’s buyer didn’t just need an FSC certificate; they needed an FSC certificate with a scope covering kraft liner board, an active status in the FSC database, and a license code that matches the mill’s invoicing entity. Certificate integrity creates that specific, defensible proof.
The mill-first principle applies here. Process capability at the manufacturing source determines whether the paper can consistently meet your specifications, but certification integrity determines whether you can legally and contractually sell products made from that paper into regulated markets. Both layers matter, and verification of the second layer is faster and more objective than auditing the first.
FSC vs PEFC: What Buyers Must Verify (and Suppliers Must Show)
The Forest Stewardship Council (FSC) and the Programme for the Endorsement of Forest Certification (PEFC) are the two dominant chain-of-custody systems for paper products. Both trace fiber from certified forests through manufacturing and trading to ensure products sold with eco-labels meet defined sourcing standards.
The key difference for kraft paper buyers: FSC has broader recognition in North American and European consumer markets, particularly for branded packaging. PEFC has stronger coverage in European forestry regions and is often preferred by mills sourcing from certified European woodlands. Neither system is inherently “better”—the choice depends on your customer’s requirements and the markets you’re selling into.
What Buyers Must Verify
Start with the public registries. FSC maintains a searchable certificate database with advanced search capabilities, and PEFC operates one at pefc.org. Enter the mill’s exact legal entity name or certificate code. If the certificate doesn’t appear, or if the status shows as “withdrawn” or “suspended,” the mill cannot legally make FSC or PEFC claims on invoices or delivery documents.
Check the certificate scope carefully. The scope section lists which products and production sites are covered, along with the control system type (transfer, percentage, or credit). A certificate for “unbleached kraft paper and sack kraft” doesn’t authorize claims for bleached kraft liner. If your spec requires a specific grade that isn’t explicitly named in the scope, the mill’s FSC or PEFC claim is invalid for your purchase.
Verify the chain-of-custody code matches the invoicing entity. Mills often have multiple legal entities (a manufacturing company, an export trading arm, a regional sales office). The FSC or PEFC license code on your invoice must belong to the exact entity issuing that invoice. Mismatches indicate the selling entity doesn’t hold the certification, even if an affiliated mill does.
Understand claim types. FSC and PEFC allow different claim categories—100% certified, Mix, Recycled, or Controlled Wood. Your invoice should specify which claim applies. If your customer requires 100% FSC but the mill’s certificate only covers FSC Mix, you’ll need to source elsewhere or renegotiate the spec.
What Suppliers Must Show
Provide the current certificate as a PDF, clearly showing the certificate number, issue and expiry dates, scope of products, and the certifying body’s accreditation mark. Don’t send a certificate that expired three months ago with a note that “renewal is in progress.” Buyers can’t accept that risk.
Include a direct link to your live registry entry. This takes five seconds and eliminates the buyer’s need to manually search, reducing their verification time and building immediate trust. For example, share your FSC database URL showing active status.
Map your certificate scope to the buyer’s product inquiry. If a buyer requests a quote for 80 GSM MG kraft and your FSC scope covers “machine-glazed kraft paper 60-120 GSM,” explicitly state that in your quote. If the scope doesn’t cover it, acknowledge the gap upfront and explain whether you can source from a certified sister mill or if the product simply can’t carry the claim.
Issue invoices from the certified entity. If your FSC certificate is held by “ABC Paper Mills Pvt Ltd” but your invoices come from “ABC International Trading LLC,” the claim won’t stand up to a buyer’s audit. Either transfer the certificate to the invoicing entity or route the sale through the certified one.
ISO Certifications That Actually Matter for Kraft Paper
ISO certifications signal that a mill operates under documented, audited management systems. For kraft paper sourcing, three ISO standards are particularly relevant: ISO 9001 for quality management, ISO 14001 for environmental management, and ISO 22000 for food safety management.
ISO 9001 is table-stakes for any serious kraft paper mill. It demonstrates the mill has documented procedures for process control, calibration, corrective actions, and internal audits. This doesn’t guarantee the paper will meet your spec—it guarantees the mill has a system to manage quality consistently and address nonconformances when they occur.
ISO 14001 shows the mill manages environmental impacts through documented programs for waste reduction, emissions monitoring, and compliance with local regulations. Many buyers in Europe and North America now require ISO 14001 as a minimum, particularly for packaging applications where brand owners face increasing pressure to demonstrate sustainable supply chains.
ISO 22000 or FSSC 22000 apply when kraft paper contacts food or is used in food packaging structures. These standards extend ISO 9001 with specific requirements for hazard analysis, critical control points (HACCP), and contamination prevention. Not every kraft paper mill needs ISO 22000—it’s relevant primarily for grades used in direct food contact (like greaseproof or food wrapping papers) or as inner layers in food-contact packaging structures.
Scope Wording Alignment
The certificate’s scope section lists which products, processes, and sites the certification covers. A mill’s ISO 9001 certificate might state: “Manufacture of unbleached kraft paper, kraft linerboard, and sack kraft, 60-200 GSM, at Site A.” If you’re buying bleached kraft from Site B, that certificate provides no assurance.
Read the scope language carefully. Vague phrases like “manufacture of paper products” don’t provide meaningful assurance. Specific product names (kraft linerboard, MG kraft, sack kraft) and GSM ranges offer clarity. If your spec falls outside the stated range, ask whether the mill has a supplementary certificate or whether the product simply isn’t covered.
Group certificates and multisite structures are common in the paper industry. A parent company might hold a single ISO certificate covering multiple production facilities. When reviewing such certificates, ensure the specific mill that will produce your order is explicitly listed in the scope’s site coverage section.
Check the test method frameworks mentioned in quality certificates. Mills with ISO 9001 often reference TAPPI or ISO test methods for basis weight (TAPPI T 410, ISO 536), burst strength (TAPPI T 403, ISO 2758), and tensile strength (TAPPI T 494, ISO 1924). Alignment between the mill’s stated test methods and your incoming inspection methods prevents disputes over whether delivered material meets spec.
Certificate Validity and Accreditation
Verify the certificate is current. ISO certificates are typically valid for three years, with annual surveillance audits required to maintain status. If the certificate shows an issue date more than three years ago with no recent surveillance audit stamps, the certificate may have lapsed.
Confirm the certifying body is accredited. Look for an accreditation mark from a recognized body like UKAS (United Kingdom), ANAB (United States), or a member of the International Accreditation Forum. Certificates issued by non-accredited bodies may not be accepted by your customers or their auditors.
Food-Contact Compliance: What Counts as Proof
When kraft paper is used in food packaging—whether as a direct contact layer, a ply in a multi-layer structure, or a bag for dry goods—it must comply with food-contact regulations in the markets where the final package is sold. The two major regulatory frameworks are the European Union’s materials and articles framework and the U.S. Food and Drug Administration’s food additive regulations.
In the United States, FDA 21 CFR Parts 174-176 govern components of paper and paperboard intended for food contact. General provisions appear in § 174.5, while specific substance-use sections reside in Part 176 (Indirect Food Additives: Paper and Paperboard Components). These regulations list which substances are permitted in paper and paperboard that contacts food, along with any usage limitations or migration limits that apply.
In the European Union, Regulation (EC) No 1935/2004 establishes the general safety requirement that all materials and articles intended for food contact must not transfer constituents to food in quantities that could endanger human health or cause unacceptable changes in the food’s composition or organoleptic properties. While plastics have specific EU measures, paper and paperboard rely on this framework plus national measures and supply-chain testing protocols. EU 2023/2006 sets out Good Manufacturing Practice (GMP) requirements for materials and articles, and suppliers often align their hygiene controls, traceability, and contamination prevention programs with these GMP principles.
What Counts as Proof
A Declaration of Compliance (DoC) is the primary document. This is a formal statement from the mill (or the converter, depending on who places the product on the EU market) declaring that the paper complies with applicable regulations. The DoC should list the relevant regulations (e.g., EU 1935/2004, EU 2023/2006, FDA 21 CFR 176.170 for paper in contact with dry food), the product it covers, and any conditions of use or restrictions.
A DoC alone isn’t enough. It must be backed by migration testing or compositional analysis from an accredited laboratory. Migration testing simulates food contact conditions (specific food simulants, time, and temperature) and measures whether any substances transfer from the paper to the simulant above regulatory limits.
Common tests include overall migration (total transferred mass), specific migration (for identified substances like certain adhesives or coatings if present), and sometimes heavy metals analysis or fluorinated compound testing depending on the paper treatment and end use.
The testing must be recent and relevant to the actual product. A five-year-old test report for unbleached sack kraft doesn’t validate a newly introduced bleached MG kraft. As a general guideline, migration tests should be refreshed when the product formulation changes, when the supplier changes raw material sources, or at least every two to three years to align with typical shelf-life and regulatory review cycles.
Who Holds the Evidence?
For commodity kraft paper sold as a raw material (rolls, sheets, reels), the mill is responsible for providing the DoC and supporting test data. The mill must ensure the paper composition and manufacturing process comply with food-contact regulations.
For converted products (printed or coated kraft, formed into bags or boxes), the converter often takes on the compliance responsibility because they’re adding layers (inks, adhesives, coatings) that could introduce migration risks. In this case, the converter issues the final DoC, but they’ll require upstream DoCs and data from the kraft paper mill to support their own compliance declaration.
Clarify responsibility early in the sourcing process. If you’re a converter buying kraft paper to make food-contact bags, confirm the mill will provide a DoC and test reports that cover the base paper. If you’re a brand owner buying finished kraft bags, confirm the converter holds the final DoC and has documented evidence from all upstream suppliers.
30-45 Minute Verification Workflow (Buyer-Ready Checklist)
This checklist provides a systematic process to verify a kraft paper mill’s certifications before you shortlist them or issue a purchase order. The workflow takes approximately 30 to 45 minutes per supplier if you have the right information upfront.
Step 1: Request the Evidence Pack (5 minutes)
Send the supplier a single, clear email requesting:
- Current FSC or PEFC certificate (PDF)
- Current ISO 9001, ISO 14001, and ISO 22000 certificates (if applicable)
- Declaration of Compliance for food-contact applications (if applicable)
- Supporting migration test reports or compositional analysis (if applicable)
- Direct registry links for FSC/PEFC lookup
Step 2: Validate Against Official Registries (10 minutes)
Open the FSC database at fsc.org or the PEFC registry at pefc.org. Search by the mill’s exact legal name or certificate code. Confirm the certificate status is “Active.” Download or screenshot the registry entry showing the current status and scope for your records.
For ISO certificates, verify the certifying body is accredited by checking the International Accreditation Forum’s database or the certifying body’s own accreditation statement. Confirm the certificate issue and expiry dates are current.
Step 3: Check Scope Alignment (15 minutes)
Compare the product names and specifications in the certificate scope to the kraft paper grades you’re sourcing. Make a simple table:
| Your Requirement | Certificate Scope | Match? |
| 80 GSM Bleached Kraft | “Unbleached kraft paper, 60-120 GSM” | No – bleaching not covered |
| 125 GSM Kraft Liner | “Kraft linerboard, 100-200 GSM” | Yes |
If there’s a mismatch, document it and either adjust your spec, request clarification from the supplier, or move to another mill.
For food-contact applications, verify the DoC explicitly names the product you’re buying and lists the relevant regulations. Check that the test reports are dated within the last two to three years and were conducted by an ISO 17025-accredited lab.
Step 4: Map to Your Specification (10 minutes)
Cross-reference the certified products with your technical spec. Does your spec call for 110 GSM kraft liner with a Cobb value below 25 g/m²? Check whether the mill’s ISO 9001 scope covers kraft liner in that GSM range. Check whether their test method references (TAPPI T 441 for Cobb) align with your incoming inspection methods.
If the mill references different test methods, note it for discussion. Testing TAPPI T 403 for burst versus ISO 2758 usually yields comparable results, but it’s worth confirming the mill can provide data in the format your QA team uses.
Step 5: Log Your Decision (5 minutes)
Record the outcome in a supplier qualification tracker. Note the certificate numbers, expiry dates, scope limitations, and any gaps. This documentation is essential when your procurement or legal team asks, six months later, why you selected (or rejected) a particular supplier.
If the supplier passes verification, proceed with sampling and commercial negotiations. If they fail due to expired certificates or scope gaps, communicate the specific issue clearly and ask whether they can remedy it (e.g., by renewing the certificate or extending the scope via an audit addendum).
Supplier Playbook: How to Present Audit-Ready Evidence
For kraft paper mills and exporters, the goal is to organize your certification evidence so that buyers can verify it quickly and confidently. This reduces qualification time, minimizes follow-up requests, and positions you as a professional, low-risk partner.
Create a certification evidence matrix that maps each product SKU or grade family to its relevant certifications. For example:
| Product | FSC/PEFC | ISO 9001 Scope | ISO 14001 Scope | Food-Contact DoC | Test Reports |
| KLB 125 GSM | FSC-C123456 (Mix) | Yes, Site A | Yes, Site A | EU 1935/2004 + FDA 21 CFR 176.170 | Report dated 2024-03-15 |
| Sack Kraft 80 GSM | PEFC-C654321 (100%) | Yes, Site A | Yes, Site A | EU 1935/2004 | Report dated 2023-11-20 |
This matrix becomes your master reference. When a buyer asks about a specific grade, you can immediately point to the relevant row and provide direct links or attachments.
Maintain version control on all certificates and test reports. Each document should include a clear version number or date stamp. When you renew a certificate or update a test report, archive the old version and clearly mark the new one as “Current.” This prevents confusion when a buyer references an old certificate they downloaded from your website three months ago.
Provide direct registry links in every quote and proposal. Rather than saying, “We hold FSC certification,” include a hyperlink: “Our FSC certificate (FSC-C123456, status: Active) can be verified here: [direct URL].” This takes you five seconds and saves the buyer ten minutes of searching.
For food-contact products, prepare a compliance summary sheet that lists:
- Applicable regulations (EU 1935/2004, FDA 21 CFR Part 176, etc.)
- Test report date and reference number
- Testing laboratory name and ISO 17025 accreditation number
- Conditions of use or limitations (e.g., “suitable for dry food contact only” or “max contact temperature 40°C”)
Attach this summary to every quote for food-contact kraft. Buyers will appreciate the clarity, and it signals that you understand compliance requirements.
Evidence Pack Cover Letter Template
Use this copy-ready format to assemble a comprehensive evidence pack:
Subject: Certification & Compliance Evidence Pack — Kraft Paper Grades [List Grades]
From: [Legal Entity]; Sites: [Mill A], [Mill B]
Contact: [Quality/Regulatory Lead, email/phone]
Certificates & Registrations
- FSC CoC: [Code]; Scope: [Paper/Board, sites]; Issue: 2026; Expiry: 2026; CB: [name]
- PEFC CoC: [Code]; Scope: [Paper/Board, sites]; Issue: 2026; Expiry: 2026; CB: [name]
- ISO 9001/14001/22000: [Codes]; Sites: [list]; Issue/Expiry: [dates]; CB: [name]
Food-Contact Compliance
- DoC applicable to: [direct/indirect], [food categories], [time/temp]; Basis: [21 CFR Part 176 / EU 1935/2004]
- Test Reports: [Lab], [Accreditation], [Report IDs], [Dates], [Simulants & Conditions]
Included Attachments: Certificate PDFs, database extracts, DoC, test reports, product spec, COA template.
Common Red Flags and How to Resolve Them
Certain patterns during certificate verification indicate a supplier isn’t audit-ready or may be presenting misleading claims. Here are the most common red flags and how to address them.
Red Flag 1: Certificate Status Shows “Withdrawn” or “Suspended”
If the FSC or PEFC registry shows a withdrawn or suspended status, the mill cannot legally make chain-of-custody claims, even if they still have a physical copy of the old certificate. The most common cause is failure to complete annual surveillance audits or unresolved nonconformances.
Resolution: Ask the supplier for a clear timeline to reinstate the certificate. FSC and PEFC allow reinstatement, but it requires a re-audit and corrective action closeout. If the supplier can’t provide a concrete date, assume the certificate won’t be available and look elsewhere.
Red Flag 2: ISO Certificate Shows an Outdated Standard Version
ISO standards are periodically revised. For example, ISO 9001:2015 replaced ISO 9001:2008. A certificate showing “ISO 9001:2008” in 2025 indicates the mill hasn’t transitioned to the current version, which raises questions about whether their management system is up to date.
Resolution: Confirm whether the certifying body has issued a transition plan or if the mill is operating under an extension. If the certificate is genuinely outdated, request proof of ongoing transition or consider it a gap.
Red Flag 3: Declaration of Compliance Without Supporting Test Data
A DoC that simply states “This product complies with EU 1935/2004” without attaching migration test reports or compositional analysis is insufficient. The DoC is a claim; the test data is the proof.
Resolution: Request the underlying test reports. If the supplier says testing isn’t required because “it’s just paper,” that’s incorrect—any material intended for food contact requires evidence of safety. If they can’t provide it, they’re not compliant.
Red Flag 4: Test Reports Older Than Three Years
Migration testing should be current. If the only test report available is from 2019, it doesn’t account for potential changes in raw materials, process conditions, or regulatory limits that have occurred since.
Resolution: Ask when the next test is scheduled. If the supplier has no plan to refresh testing, flag this as a compliance gap. Many buyers establish a policy that test reports must be less than two or three years old to be acceptable.
Red Flag 5: Scope Gaps Between Claimed Products and Certified Products
The supplier’s sales brochure lists ten kraft paper grades, but the FSC certificate scope covers only three. This indicates they’re making FSC claims on products that aren’t certified.
Resolution: Ask for explicit confirmation of which grades are covered by the certificate. If you need a non-covered grade, confirm whether the mill can extend the scope through an audit addendum or whether you’ll need to source that grade as non-certified.
Red Flag 6: Entity Mismatch
The certificate holder’s legal name differs from the entity issuing the invoice or sales contract. For example, the FSC certificate belongs to “ABC Paper Mills Ltd” but invoices come from “ABC Trading International.”
Resolution: Obtain clarification on the legal entity structure. If the invoicing entity doesn’t hold the certificate, they cannot pass on certified claims. Either switch to invoicing from the certified entity, or have the trading entity obtain its own chain-of-custody certificate covering the transaction.
How PaperIndex Helps (Education + Discovery, Not Brokerage)
PaperIndex is a neutral, non-transactional B2B marketplace connecting kraft paper buyers and suppliers across 195 countries. The platform is designed to simplify supplier discovery and lead generation without acting as a broker or intermediary.
For buyers, PaperIndex offers free access to find kraft paper suppliers, including detailed profiles of kraft paper manufacturers and kraft paper exporters. You can submit RFQ requests to multiple suppliers simultaneously and receive quotes directly, with no commissions or transaction fees.
The PaperIndex Academy provides educational resources to help both buyers and suppliers navigate complex topics like certification verification, international trade documentation, and quality assurance processes. Related guides include factory audit for kraft paper manufacturers, kraft paper manufacturers capability matrix, and the mill-first rule for evaluating kraft paper vendors.
PaperIndex does not sell market intelligence, publish pricing indices, or act as a broker. All negotiations, pricing discussions, and transactions occur directly between buyers and suppliers. The platform’s role is strictly to facilitate connections and provide educational resources that make those connections more effective.
Frequently Asked Questions
Which certifications matter for kraft paper manufacturers?
For most buying programs: FSC or PEFC chain-of-custody for fiber traceability; ISO 9001 for process control; ISO 14001 for environmental management; and food-contact compliance evidence (Declaration of Compliance plus test reports) when the paper will contact food. FSC proves the fiber is traceable to certified forests, but it doesn’t validate the mill’s quality management system or process control. ISO 9001 provides that assurance. For food packaging applications, ISO 22000 becomes relevant as well.
How do I verify an FSC/PEFC certificate is valid and in-scope?
Look up the certificate in the FSC or PEFC public databases and match status, sites, and product groups to the supplier’s claims and the specific mill that will produce your order. The certificate must show “Active” status, and the scope must explicitly cover the grade you’re buying (e.g., bleached kraft liner 100-200 GSM). Check that the legal entity on the certificate matches the entity issuing your invoice.
Do exporters need their own chain-of-custody certificate?
If an exporter or trader takes ownership of the paper and issues invoices with FSC or PEFC claims, that entity typically needs its own chain-of-custody certificate covering the product group and transaction. This is called “transfer of custody.” If the exporter is simply a sales agent and the mill invoices the buyer directly, the mill’s certificate covers the transaction. When in doubt, verify that the invoicing entity’s name matches the certificate holder.
What proves food-contact safety for kraft paper?
A Declaration of Compliance naming the regulatory basis (e.g., FDA 21 CFR Part 176 for the US, or EU 1935/2004 for Europe) plus migration or analytical test reports from an ISO 17025-accredited laboratory for relevant grades and intended conditions of use. The DoC is the formal claim; the test reports are the evidence. Both are required. The test reports should be recent (typically less than two to three years old) and specific to the grade you’re buying.
How often should migration test reports be refreshed?
Refresh testing when there are material changes (raw material chemistry, supplier changes, process modifications) or periodically per your food safety management system or customer requirements. Generally accepted practice is to refresh at least every two to three years, or more frequently if your specification or risk assessment requires it. Align refresh intervals with ISO 22000 procedures and customer risk appetite. Stale test reports (older than three years) often trigger requests for updated testing during qualification reviews.
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