Is There an Expiration Date for Certificates of Compliance?

We’re often asked about the “expiration date” for test pieces and/or certificates.  Certificates are dated when they were last updated, for whatever reason.  For instance, we updated our certificates at the beginning of last year, so they are dated January 1, 2023.  We modified the wording to make it a bit easier to read and more specific as to what is technically being certified.  They may not require any further updates for the foreseeable future.  Regulations may change at which time we may need to update the certificates.  And even new lot numbers are typically given the same date as other certificates, because that is the date under which the certification process was clearly in place.

The only reason for an expiration date to occur on a metal detection or x-ray inspection test piece would be that it has incurred some type of damage or exposure of the contaminant inside the test piece.  As long as the contaminant, whether metal or some other form of contaminant used in x-ray inspection applications, remains encapsulated, the certificate remains valid.  The metal detector signal and x-ray attenuation produced from these products does not deteriorate over time.

As for the “container” (acetal, laminate or thermoform), it will always be food grade safe unless by age, deterioration or abuse from the application, it begins to break apart within the food production or packaging process.  In a good quality control plan, a test piece like this would, of course, be removed from the production line and be replaced with a new one.  There really is no expiration for the certificate, but it becomes valueless for that particular test piece since it will no longer be in production anyway.

There are companies who claim there is an expiration date on certificates and then update their documents annually.  It give them a basis for charging a fee for the updated certificates. This places an unnecessary burden on your paperwork load, especially if you’re in a large plant with a variety of products and an array of sizes and types of metal or other contaminant.  In a free market economy, it’s not illegal, but some would argue that at best, it’s misleading and even dishonest.

Unfortunately, some auditors don’t understand the certification and “non-expiration” nature of test pieces.  What’s important is that the “container” is food grade safe and that the contaminant inside meets the necessary specifications for size and type.  In other words, if the container indicates that there is a 2.0mm Stainless Steel 316 seed inside, then that seed should meet the requirements of the industry.  The lot variation for size should be on the certificate as well as its composition or chemical analysis where applicable.

At Regal Packaging Services, we get calls on a semi-regular basis from customers who tell us their auditors want “new” or “updated” certificates with the current year displayed.  And if the auditor is adamant that the certificate must be updated, we will honor a customer’s request for a nominal fee just to cover our time in preparing the altered certificate.

But the auditor’s request is akin to telling you that you need a new water bottle every year even though you’ve kept the old one clean and sanitized and there are no better ones on the market. It’s a specious request.  It sounds like a good idea when there’s really no reason for it.  And that is not meant to discredit any auditor.  We welcome any calls (whether from a customer or auditor) regarding the nature or substance of our “no expiration” claim as stated on our certificates: “ The metal detector signal and x-ray attenuation produced from these products does not deteriorate over time and our certificates do not expire.”

Just call us at 866-691-8560 or email us at testrods@testrods.com for questions and more information.  See more about Regal Packaging Services at regalpack.com and detectoraudits.com.