In the first article we looked at clause 5.2.1, if you’ve seen it, you can catch-up here: Product Labelling – part 1

BRC Food Safety – 5.2 Product Labelling Continued….

Clause 5.2.2

There shall be effective processes in place to ensure that labelling information is reviewed whenever changes occur to:

  • the product recipe
  • raw materials
  • the supplier of raw materials
  • the country of origin of raw materials
  • legislation

This clause is pretty straight forward, it’s basically a clause to catch any issues raised during your audit, because in order for the auditor to give you a non-conformance they have to assign a relevant clause. So this clause catches any issues when labelling hasn’t been updated when there has been a change.

It doesn’t require that you have a documented procedure, it just says you have to have an effective process in place.

However it would be a really good idea to have the requirements of this clause written into your procedures that cover changes to ingredients, recipes and processes – to ensure changes are acted upon.

The aim of this clause is to make sure that once any printed packaging or labels are set, any changes to the product from then on prompts a review of the label, before the changes are made – to ensure that the label is always up-to-date.

Packaging & Labelling

Changes which should prompt a review of the label are:

1.  Changes to ingredient suppliers, examples such as:

  • even if you are purchasing the same ingredient, but from a different supplier, the components in that ingredient may be different from supplier to supplier, which may change your ingredient declaration or QUID
  • plus the allergen information from the new supplier may be different, the ingredient may contain different allergens, or the way in which the new supplier processes the ingredient may mean that are different cross contamination risks from allergens that you’d need to take into consideration for “may contain” on the label
  • the shelf life of the ingredient from the new supplier may be different, which may impact on the shelf life of your finished product and so coding on the labelling
  • the country of origin may change, which may change claims on pack, such as beef burgers made with British beef

2.  Changes to the recipe

  • if the quantities of the ingredients in the recipe change, it may mean that changes are required to the ingredient declaration or QUID
  • recipe changes may mean any nutritional claims on pack are affected, or the nutritional composition per 100g or portion is effected

3.  Changes to the process

  • something as simple as baking a product through a different oven may change the finished weight of the product, which will change the declared pack weight and could change the serving size, in turn may change the nutritional per portion and possibly the QUID
  • the way in which something is made may change the descriptive information on pack, such as a hand made claim
  • the introduction of another product to a process, which contains a new allergen may effect all the other products on that line, or in areas where they come into contact/close proximity – and so, changing the “may contain”
  • engineering modifications to cooking equipment could have a serious impact on food safety and so use by on pack or cooking instructions

Trying to make sure these changes are highlighted at the right time isn’t always easy as they are generally initiated by different departments, and those concerned may not be aware of how their actions may effect the labelling of the finished product.

It’s important that the systems that are in place prompt them to highlight it.

You could do this by:

  • adding a label review check to the HACCP review process
  • ensuring requests to change internal (factory) process specs or recipes, have to go through an approval process which include a label review
  • ensuring any management sign off for capital (such as engineering work) goes through an approval process which includes a technical sign off
  • ensuring modifications to equipment which manages food safety goes through an approval process
  • ensuring procurement changes have a technical sign off, if purchasing is managed by an electronic purchasing system this could be automated to stop changes being made without the correct authorisation

Overall the most important thing to remember is that the change must be notified and the labelled changed, before the change is implemented, to ensure that the product labelling is always up to date.

Clause 5.2.3

Where a product is designed to enable a claim to be made to satisfy a consumer group (e.g. a nutritional claim, reduced sugar), the company shall ensure that the product formulation and production process is fully validated to meet the stated claim.

This clause only applies if to products if they have a nutritional claim on pack.

To comply with this clause you need to provide both validation and verification evidence for the nutritional that supports your claim.

To validate ideally this should be done by taking at least a total of three factory samples from three runs (one from each) and sending these off for nutritional testing. The results of these should firstly be compared to check that the range of results is not too wide, as this would indicate that the recipe or process is not sufficiently in control – and if this was the case the reason for this would need to be resolved, and then the validation process repeated. If the results are within about 5% of each other then the results can be used and to do this average the three results to get the final result for the label.

To verify the nutritional claim, nutritional testing should be carried out routinely. Please note the standard only says verification is good practice, which indicates it’s not a must do requirement.

It’s up to you to decide the frequency of the testing as there is no set standard, however I would suggest annually to start with.  When you receive the verification results (nutritional testing certificate), they should be compared to the figure on pack and they should be within a set range of the pack figure to be acceptable – +/-5% would be a sensible starting point for this range.  Please check though if any of the legislation for your claim provides you with an acceptable range, if there is – this should be used.  If the results are outside the acceptable range, corrective action would need to be taken – to do this you could repeat the testing and if the results were unacceptable again, then steps would need to be taken to repeat the validation and change the labelling.

Clause 5.2.4

Where the label information is the responsibility of a customer or a nominated third party the company shall provide:

  • information to enable the label to be accurately created
  • information whenever a change occurs which may affect the label information

This clause is only for labels which are generated by your customers for you (for their brands) or if you use a third party/ consultant to work out your label pack copy.  The clause is designed to ensure that the information that you provide your customer or third party is accurate (otherwise the label will not be accurate) and that if anything changes to the recipe or process as discussed above you must notify them – remember this must be done before the change takes place.  This clause ensures that the manufacturer takes responsibility for the content of the product labelling.

If you have any comments on this article, or would like us to cover any specific topics, just leave us a comment below.

And don’t forget to check out some of the other articles for product labelling & packaging

Have your say…

8 thoughts on “Product Labelling part 2

    1. Hi Julie, thank you I’m really pleased you find it useful. Two votes for 6.2 Labelling and pack control – think that will be the one! 🙂

  1. I think these newsletter updates are a great idea. Please keep them coming. Definitely 6.2 Labelling and Pack control for me!! Thanks

    1. Thanks Nick, we will keep posting them every fortnight, it’s great to hear you find them useful! Labelling it is!

  2. Hello Kassy,

    We ran into difficulties with the 5.2.4 clause in our first BRC audit. We are located in the US and our customers’ products are sold in the US as well. We only have one retail product of our own which we scrutinize as the standard dictates. However, our auditor claimed WE needed to show evidence that OUR CUSTOMERS’ labels were validated as well. We tried to put our 50+ client’s labels through our program which covered all the bases: nutrition claims, certifications, nutrition facts, etc. We realized that this was a HUGE task we couldn’t do. In hindsight I think we could have protested this to BRC but since we were new and inexperienced did not know.
    Do you have any language you could suggest for how to deal with co packing clients on our Label verification SOP which would cover 5.2.4?

    1. Hi, hope you’re well?
      It sounds like your auditor has understood this clause – as the clause only requires you to be able to provide your customer with accurate information, rather than, checking that the customer has used that information accurately. You need to make sure you can show that you have a way of providing the information accurately (through specs for example) and that when a change occurs, that the spec is updated and sent to the customer before the change occurs. This needs to be in writing and sent to the customer so that you can show they understand the process (you can do this by emailing it to them and keeping evidence of the email, in case they don’t reply). The only other point you could add to this clause (although it doesn’t ask you to do this), is to get someone to cross-check the spec you send the customer with the label that they generate, before launch. And then, sign off to say you’ve done this.
      I hope that helps.

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