The following position statements are shown in date order, most recent first.

To see the position statement documents, click on the link in the document details column. Changes from the previous version are highlight in yellow.

Last reviewed 25th March 2021

All COVID-19 related position statements are now stored in one place: What are the options for BRCGS audit during COVID-19?

Document details

Purpose

Version 3: 12th March 2021 (NEW)

BRCGS089 Unnanounced

Version 3

Additional 60 minutes allowed for covid requirements (e.g. auditor testing).

Version 2.1

Date for suspension of unannounced audits extended until 31st Dec 2021.

Version 1: 5th March 2021

P618 Position statements for Issue 6

Version 1.1 (NEW)

Replaces position statements; P614 (disposable packaging), P616 (functional claims), P617 (allergens) and P552 (defence and fraud).

Clarifies that both product defence (threat assessment) and product fraud systems (vulnerability assessment) are required for packaging – no major changes from the text in P552.

Clarification as to whether the packaging standard or the consumer products standard is the best fit for certain disposable packaging items – no major changes from the text in P512.

Change to the addition of clause 3.4.3 – this addition, has now been moved from clause 3.4.3 to 3.4.1. The additional part of the clause now states that the functional requirements must be specified in the specification, NOT in the statement of compliance (as it was before). The introductory text still references 3.4.3, but we’re presuming this is a typo and should have been changed to 3.4.1. See before and after additional part of the clause shown below in italics:

Before:

3.4.3 Where packaging for food or other hygiene-sensitive products is produced, a statement of compliance shall be maintained which enables users of the packaging to ensure compatibility between the packaging and the product with which it may be in contact.
The statement of compliance shall be compiled and authorised by a suitably competent person. It shall contain as a minimum:
• the nature of the materials used in the manufacture of the packaging
• confirmation that the packaging meets relevant legal requirements
• the inclusion of any post-consumer recycled materials.
The statement shall identify:
• its date of issue and, where appropriate, its expiry date
• any limitations of use of the product, and
• the usable life of the packaging (where relevant).
The site shall review the statement of compliance at a risk-based frequency.
Where functional packaging for food or other hygiene-sensitive products is produced, the statement of compliance shall contain documented evidence to demonstrate effectiveness or proof of effect claimed by the packaging material including extended shelf life, freshness, and temperature monitoring.

After:

3.4.1 Specifications shall be suitably detailed, accurate and compliant with relevant product safety and legislative requirements. They may be in the form of a printed or electronic document, or part of an online specification system.
Where functional packaging for food or other hygiene-sensitive products is produced, the specification shall contain reference to documented evidence to demonstrate effectiveness or proof of effect claimed by the packaging material including control and extension of shelf life, freshness, and temperature monitoring.

Change to allergen management from that stated in P617. In P617 a new section was added to the end of section 5 – 5.11 Allergen Management. The new clauses have now been added to the end of section 4.9.3 Chemical & Biological Control. There is no longer a section 5.11 Allergen Management. The clauses have also changed, see before and after below:

5.11 Allergen Management

Statement of intent: The site shall have a documented procedure to identify allergenic materials and potential routes for contamination, and based on risk, establish an effective allergen management plan.

4.9.3 Chemical & Biological Control

5.11.1 The site shall carry out an assessment to establish the presence and likelihood of allergenic materials and contamination by allergens. The assessment shall include raw materials as virgin and recycled formats, intermediate and finished products, processing chemicals, inks, solvents, and traded products. This assessment shall form part of the documented HARA as detailed in clause 2.2.6 of the Standard

This clause has been removed.

5.11.2 Where allergens have been identified as part of the hazard analysis and risk assessment, the routes for contamination from incoming goods to storage and dispatch shall be identified and documented policies and procedures for handling such materials to avoid cross contamination (cross-contact) shall be established.

5.11.3 the site shall establish, implement, and maintain a plan for the management of allergens to minimise or eliminate the risk of contamination to the packaging and meet legal requirements for labelling in the country of sale. The plan shall be reviewed based on risk.

4.9.3.3 Where allergens have been identified as part of the hazard analysis and risk assessment the routes for contamination from incoming goods to storage and dispatch shall be identified. Documented policies and procedures for handling such materials to avoid cross contamination (cross-contact) shall be established.

4.9.3.4 The site shall establish, implement, and maintain a plan for the management of allergens to minimise or eliminate the risk of contamination to and/or from the packaging and meet legal requirements for labelling in the country of sale. The plan shall be reviewed based on risk.

Version 3.1 1st March 2021 (NEW)

BRCGS080 Blended audits

Version 3.1

Added details for when your blended audit is combined with another GFSI audit. And, addition of the gluten free certificate to the blended audit option.

Version 1

Details on how to complete a BRCGS blended audit, which is part remote and part on site.

Version 2.1

New protocol for sites which have very short seasons. S&D sites have the option to choose fully unannounced, or part announced on the year that it’s due.

Version 1.1

Outlines the requirements for announced sites to have 1 unnanounced audit every 3 years.

Have your say…

15 thoughts on “Position Statements BRC Packaging

  1. This is great work done by Techni-K team, congrats….., I have been working on BRC Packaging since its 1st Issue but this site is most resourcefulness than any other before and currently. We appreciate the research and information disseminated.

  2. Hello,
    where can I find Position Statement BRCGS082? It’s not on BRC website.
    I’ll appreciate the help.
    And congratulation for your work. It’s really helpful

    1. Hi Keara
      Position statement 557 is written against issue 5 and therefore becomes invalid against issue 6.
      Unfortunatley, BRCGS don’t have a document control system which removes such documents when they are no longer valid (it’s one of my bug bears that they don’t follow their own rules).
      Thanks
      Kassy

  3. Thank you for this heads up. It is much appreciated.
    I am reading P617 Allergen Management Control and just have a query.
    There are 14 food allergens which are part of food law currently but LATEX is not one of them. Why is that in the document? I will of course look at all our materials again and consider soy & wheat etc. but do we really need to get into whet the valves, belts, o rings etc. I realise you are only the messenger and did not intent to shoot you. 🙂

    1. Hi Sharon,
      You raise a very good point, for which I have no answer to! You’re right that latex is not one of the 14 EU allergens. It’s a known allergy. However, it’s not generally eaten (?!) so I suppose you wouldn’t expect it to be listed with the 14 food allergens.
      It raises a very valid point – that for packaging sites, what do they class as an allergen in their risk assessment? If the scope isn’t just the 14 food allergens, then where do you stop? And, where would we get the source information from that states what allergens should be within scope?
      I’m sure one of our packaging specialists will add to this conversation…
      Kassy

  4. Ok, so no need to worry about belts and valves and o-rings. The clause 5.11.1 stipulates that this relates only to raw materials (of packaging). I would simply ask your packaging material suppliers to verify this. Latex is used in inks (the scratch off type) but as I recall it is a different type of latex and does not cause allergic reactions. But employees can be allergic to latex gloves and that should be considered as part of the HACCP/HARA/HARM plan

    The Stig

    1. Thanks for this. Is there a list of known allergens that the sites should be looking at? If we’re going outside the usual 14 allergens, it leaves it open to interpetation. Surely we need some sort of agreed source of information?

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