MOCA is no certification: it is the Italian acronym for “materials and objects intended to come into contact with food”. Kitchen utensils and tableware, containers and vessels, food processing machines, packaging materials, etc.; objects and materials coming into contact with water are included as well, with the exception of fixed public or private water supply installations (ref. Ministry of Health).
Therefore, food packaging, caps, tags that may come into contact with food, utensils, ducts and pipeworks, plants and equipment, and indirect materials such as printing inks and lubricants fall within this scope.
Since 1962, Italian Law no. 283 on food hygiene provided for instructions, obligations and interdictions as for MOCA production and marketing.
Ministerial Decree of 21.03.1973, which is still in force, brought with itself instructions, obligations and interdictions that would inspire, 30 years later, the food safety concept in the European Community.
There are positive material lists (M.D. 21.03.1973) and purity standards for some materials; attention should be paid that the materials which are coming (or are likely to come) into contact with food are not releasing contaminating substances (migrations), and possible migrations resulting from temperature, sunlight and food type should be strictly monitored (oil presence, acidity, etc.).
Regulation 1935/04 is the common European framework governing this matter: among its standards, it provides for the implementation of good manufacturing practices (GMP), the obligation to apply a strong traceability system, to rely on a consistent and compliant labeling system and to produce a food conformity declaration for the materials being used.
The latter should certify food contact suitability and the compliance with applicable laws, should be produced to relevant authorities if requested and should accompany the MOCA in every step of its lifecycle, from manufacture to sale (this does not apply to retail sale with the exception of ceramic MOCA, whose declaration of conformity should be produced also at retail sale).
The manufacturer should keep the so-called “supporting documentation” proving the declared conformity, such as the declarations by raw materials producers and lab analysis results.
Plastic sector is one of the most disciplined ones (Reg. 10/2011), but national decrees have been issued for other materials as well (steel, paper and paperboard, etc.).
All the MOCA listed in Annex I of EC Regulation no. 1935/2004 and their combinations, together with recycled materials and objects, should be produced in compliance with general and specific rules on good manufacturing practices (GMP) and based on a quality assurance system (as defined in EC Regulation 2023/06). Companies carrying out any of the activities related to any stage of the production, transformation and distribution of materials and objects should implement a quality assurance and control system.
The sanctioning framework is governed by the recent Legislative Decree 29/2017.
Companies manufacturing objects which are intended to come into contact with food should check their compliance with the applicable laws and should be able to prove anytime to have performed all the necessary checks and verifications.
PI.GA. Service sas by Pironi Serena & c. offers its expert advice to support your business in properly and proactively transposing the applicable rules by channeling your resources and optimizing your processes.
GMP and traceability handbooks, food conformity declarations, labeling and assistance with the relevant supporting documents: everything is tailored on your own company.
We can also support you with the implementation of voluntary sector certifications such as BRC, IoP and IFS PACsecure.
PI.GA. strategy in regulation-compliance can be summarized by the LCDST acronym: listening, communication, design, solutions and team.
Listening to your company’s departments is vital in order to know their mechanisms and thus to spot, review and optimize the processes.
Fostering the communication among departments and planning the external communication.
Designing lay-outs, production processes, products, document management systems, analytical plans, shelf-life and planning the activities based on S.M.A.R.T. (specific, measurable, achievable, relevant and time-bound) targets.
Finding concrete and feasible solutions with regard to complaints, process and/or product issues, general non-conformities and identifying proper corrective actions in order for the problem not to come up again once the causes have been analyzed (this activity implies monitoring and the constant training of the resources).
The team lays the very foundation of a company: targets are achieved through a cohesive and expertly guided team.