Yes, It was nicely explained.
I have packaging and packaging auditing background. Asking if Micro testing is need for food packaging is a bit like asking how long is a piece of string. It depends.....
It is all about risk. It is a combination of food packaging and process. Is there a risk in packaging or food , can it be introduced through packaging. Will the risk be processed out?
If there is no risk there is not need to test. If there is a risk there is a need to test.
If you pack aseptic juice - the containter, the product and the environment in which you pack needs to be sterile. Yes.
In a can or glass where you will process up above 70 degrees. No
For milk or meat that is not further processed and prone to spoilage: Yes
For cardboard that is prone to yeast and mould: Yes
For water that is not processed but bottles are washed before filling: probably No
For containers that are not immediately blown and prone to dust with not other rinse or process: Yes
For bottles for dry herbs: Probably No as the herbs may have a higher microbial load than the bottle.
So it depends on food packaging and process.
In a nutshell there are requirements for food contact surfaces to be safe.
Also, EMP , Environmental Monitoring Plan or Program is now essential in any GFSI Food Safety scheme like FSSC 22000 version 6.
Attached are one such requirements.
And yes, all must be based on risk assessment. If you are producing packaging for direct food use like primary packaging, then as per food and other status - it needs to be highly clean both as product and as an environment in which it was produced, manufactured, transported etc.