The Kosher Issues of Generic Packaging

Continued from the last issue of The Daf Hakashrus

By Rabbi Avrohom Y. Stone
Rabbinic Field Representative

DAF NOTES: The Daf takes this opportunity to thank Rabbi Stone for this excellent article, which is his first contribution to The Daf Hakashrus.  We hope other RFR’s, as well, will begin to use The Daf as a medium for sharing with their fellow RFR’s the problems and solutions related to the dynamic field of contemporary Kashruth.

Until recently, when packaging was distinct for each item, the RFR had only to check the label room or the film storage area to determine that everything was being marked correctly.  However, with the advent of generic packaging materials, it becomes virtually impossible to discover incorrectly labeled items before they are packaged.  For example:  Coffee Company X produces numerous varieties of OU pareve coffee.  They also manufacture flavored coffees which are dairy.  In order to save money, the company orders rolls of film preprinted with their logo, design, brand name, an  and an empty space for the variety name.  The variety is imprinted on the film with a heat stamp as the item is filled.  This presents us with a serious potential problem.  Since there are dairy varieties under this brand name, it is easy for the company to mistakenly package all varieties of this brand, both pareve and dairy, using this pareve packaging, with a separate imprint for each variety.  Thus, the dairy variety will be produced without a “D” on the package, an especially great problem for someone looking for a good pareve flavored coffee to go with their roast beef sandwich.  The RFR may not discover the packaging problem, since he may not see the final version of the package.

Even if a plant is all kosher and pareve or all kosher and dairy, the possibility of misuse of generic labels still exists.  At a future date, the company may introduce a non-approved item and use the generic packaging material.  The policy issue of whether or not to allow generic labels must be decided by the OU’s Senior Management.  In the meantime, the OU requests that if we, as RFR’s, spot generic materials, we must notify the appropriate RC.  If the company is a mixed account (e.g. dairy/pareve, or kosher/non-kosher), the potential pitfalls for generic labels are immediately present and the RC should deal with this issue, in consultation with the RFR, as an emergency.

The RFR needs to analyze the implications of packaging policies with the same critical eye he uses to foresee issues involving the use of new ingredients and implementation of new manufacturing processes.

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