Jars, bottles and lids for food in BiH: what to ask your supplier for

The Vijeće ministara BiH (Council of Ministers of BiH) sets the rules on materials that touch food for the whole country, and inspectors enforce them. The rules cover jars, bottles, lids, plastic containers, ceramic tableware and film that you use for jam, honey, ajvar, juice, rakija, cheese and similar products. The rulebooks mainly bind those who make, import or sell these materials. Even so, as a food producer you need to know what you are buying and be able to prove it.

In short

• Packaging and tableware must be made so that, under normal use, they do not release into food any substances that harm health, change the food's composition or spoil its taste and smell (Pravilnik o materijalima i predmetima namijenjenim za kontakt s hranom, Službeni glasnik BiH 42/10, Article 5).
• Materials sold before they come into contact with food are marked with the words "za kontakt s hranom" (for food contact), a specific name (the rulebook's examples are "coffee machine", "wine bottle" and "soup spoon"), or the symbol in Annex II (Article 8, paragraph 1). This marking is not required for items that by their characteristics are clearly meant for food contact (Article 8, paragraph 2).
• Plastic and ceramic items must come with a written declaration of compliance issued by a manufacturer or importer registered in BiH. For plastics it is required at all stages of sale except retail (Pravilnik o plastičnim materijalima i predmetima, SG BiH 66/17, Article 15), so ask for it when you buy from a manufacturer, importer or wholesaler. Ceramics need the declaration at retail too (Pravilnik o keramičkim predmetima, SG BiH 42/10, Article 5).
• Every material must be traceable: it must be known who supplied it and who received it (general rulebook, Article 11).
• Ceramic ware has limits for lead and cadmium (ceramics rulebook, Article 4). For items that cannot be filled and vessels up to 25 mm deep: 0.8 mg/dm2 lead and 0.07 mg/dm2 cadmium. For all other fillable vessels: 4.0 mg/l lead and 0.3 mg/l cadmium. For cookware, and for packing or storage containers over three litres: 1.5 mg/l lead and 0.1 mg/l cadmium.

Who it applies to

Anyone who places on the market or uses materials meant for food contact: makers, importers and sellers of packaging, and indirectly small food producers, farm households that sell at markets, and restaurants and caterers that pack food in jars, bottles and containers.

What to do

1. Buy packaging from a registered supplier (shop, wholesaler, manufacturer) and get an invoice in your name or your company's name.
2. If an item is not obviously meant for food, for example a general-purpose plastic box or bucket, check that it has the wording, a specific name or the symbol. The rulebook does not list which items are "clearly meant" for food. If you are not sure about a jar or bottle, buy one with the marking or ask the supplier for written confirmation that it is meant for food.
3. The item, its packaging or the accompanying document should show the name and address of the manufacturer, processor or seller registered in BiH (Article 8, paragraph 1, point c, and Article 9). The label, including any instructions for use (for example "not for microwave"), must be in one of the official languages of BiH (Article 8, paragraph 5).
4. For plastic containers, film and buckets, ask for the written declaration of compliance when you buy from a manufacturer, importer or wholesaler. For ceramics, ask for it in a shop too. The declaration must show clearly which material it covers. It is renewed when significant changes in composition or production change how much of a substance migrates into food. The Agencija za sigurnost hrane BiH (Food Safety Agency of BiH) list of rulebooks in force has no separate rulebook for glass or metal, so no declaration is prescribed for glass jars and bottles. The general duty in Article 5 applies to them, and a proper invoice from a registered supplier is your proof of origin.
5. Keep the invoice, the declaration and the batch number or other marking with your production records. If an inspector comes or a batch is recalled, this is your proof of origin.
6. For plastic lids, caps and seals, migration (substances passing into the food) is tested against the container the closure is meant for. If that use is not known, the result is given per item (SG BiH 66/17, Article 17). So buy lids made for your specific jar or bottle.
7. Metal lids with a lacquer or other coating may fall under the Pravilnik o ograničavanju upotrebe epoksi derivata u materijalima i predmetima namijenjenim za kontakt s hranom (rulebook on epoxy derivatives, SG BiH 42/10), which also covers items with a surface coating (Article 2). Ask your supplier whether the coating complies with it.
8. The plastics rulebook has special rules for packaging of food for infants and young children. For such food, use packaging and tableware only if the manufacturer confirms in writing that they are meant for it.

Reusing bottles and jars

BiH rules do not specifically regulate refilling used jars and bottles. The general requirement of Article 5 applies: packaging must not release harmful substances into food or change its taste. For products you sell, use glass jars and bottles made for food, undamaged, with no residue or smell. Use new lids, because an old lid with a damaged coating or seal may be unsafe. Do not put rakija or other spirits in plastic water or soft-drink bottles. If you are unsure, ask the inspectorate.

Where to go

• Republička uprava za inspekcijske poslove (Republic Administration for Inspection Affairs, Inspektorat Republike Srpske), Područno odjeljenje Trebinje (Trebinje regional department), Republike Srpske 33, Trebinje, tel. 059/273-080. Bileća section: Vladimira Gaćinovića 2, Bileća, tel. 059/371-880. Addresses and phone numbers are on the Inspectorate contact page.
• Agencija za sigurnost hrane BiH (Food Safety Agency of BiH): list of rulebooks in force on food contact materials.

Laws and sources

• Pravilnik o materijalima i predmetima namijenjenim za kontakt s hranom (Službeni glasnik BiH 42/10)
• Pravilnik o plastičnim materijalima i predmetima namijenjenim za kontakt s hranom (Službeni glasnik BiH 66/17)
• Pravilnik o keramičkim predmetima namijenjenim za kontakt s hranom (Službeni glasnik BiH 42/10)
• Pravilnik o ograničavanju upotrebe epoksi derivata u materijalima i predmetima namijenjenim za kontakt s hranom (Službeni glasnik BiH 42/10)