Covered today – BRC changes to section 5.2 Product Labelling and the specifics around how you should provide evidence and what the auditor will be looking for.
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Anyway, enough chat, let’s get started!
5.2 Product Labelling
Overview of the section
The aim of the 5.2 Product Labelling section is to ensure that all the written text, pictures or markings on pack meet the legal requirements for the country in which it is going to be sold.
The intention of this section, is to reduce the number of incidents, including recalls which may be caused by inaccurate information on pack.
Information on the pack has to meet the legislation in the country where the product will be sold. Therefore if you export products to other countries, you will need to understand the labelling requirements for those countries. The certification bodies may ask you for more detail prior to your audit, so that they understand what countries you export to – the reason they will do this, is because they will then need to provide your auditor with the legislation information that he/she will need to check your labels against.
‘Labelling’ will cover both labelling of product that goes direct to the consumer in its current form and also labelling on product that goes to another manufacturer.
However, the detail of the labelling that goes to the consumer will be audited in much more detail, as labelling of product (or ingredients) that go to another manufacturer will contain much less detail and generally will just need to meet the specification agreed with the customer. For the purposes of this update, we are going to just focus on labelling that is seen directly by the consumer.
Let’s talk through each of the clauses individually…
5.2.1 All products shall be labelled to meet legal requirements for the designated country of use and shall include information to allow the safe handling, display, storage, preparation and use of the product within the food supply chain or by the customer. There shall be a process to verify that ingredient and allergen labelling is correct based on the product recipe and ingredient specifications.
This clause can be broken down into three main parts:
- All products shall be labelled to meet legal requirements for the designated country of use
- Shall include information to allow the safe handling, display, storage, preparation and use
- Shall be a process to verify that ingredient and allergen labelling is correct based on the product recipe and ingredient specifications
1. All products shall be labelled to meet legal requirements for the designated country of use
So, as we’ve discussed earlier this means that the labelling must meet the legal requirements of the country where the product is to be sold. You therefore need to be aware of these requirements. Be aware – you may be asked to provide evidence that you have copies of the legislation of those relevant countries and you would need to either be able to translate them, have had them translated or have a way in which a third party looks after this for you.
The legislation even just in the UK is vast with regard to labelling, to try to know and understand all of the finer details of the legislation is really difficult. It is therefore advisable to use a third party to help you do this, who have to the knowledge to be able to provide you with the information that you need. A third party can help you put your pack copy together (a pack copy contains all the detail that the company generating your artwork will need to print your printed packaging/labels) and can also help you check your artwork to make sure it’s correct. If you need assistance with this, we can help you too.
2. Shall include information to allow the safe handling, display, storage, preparation and use
This is talking about the information that you give the customer to explain to them how they should handle your product. For example, this would include:
- Safe handling – this would be warnings such as ‘this product may be hot’ (you may have seen this type of warning on coffee)
- how to store it – cool and dry conditions, in the fridge, in the freezer
- how long to store it – this will include the best before or use by and if it can be frozen, how long it can be stored frozen for
- how long to display it for – this would be the ‘display until’ date (how long it can be kept on the shelves for and if it’s not sold in this time it must be removed)
- preparation and use – this would include instructions for how the consumer should prepare the product to eat, so typical example of this would be cooking instructions
All of the above information would be defined by you as a manufacturer. Because you define what should be put on pack, you need to be able to provide evidence as to how you decided that the information you have defined is correct.
For storage conditions you’ll need to provide evidence of how you decided on the storage conditions were acceptable – to do this you’ll need to be able to provide at least one set of micro testing results for the product up to the end of life at the specified storage conditions. It is a good idea when carrying out micro tests for this purpose to actually store the product at the worst case and document that you do this in your procedure. For example, if you are labelling your product ‘store chilled’ – generally this is expected to be between 4 and 8°C. Most consumer’s fridges run at the higher end of this scale, or even warmer. So to really challenge the product and make sure it is safe during the storage period, it would be a good idea to store the product to be tested at 8°C. It is also a good idea to test slightly over the defined shelf life – so that you can prove that it definitely is ok, so if your product has a 10 day shelf life, test it up to 11 for example.
Cooking instructions are key – make sure that you have carried out more than one trial at the instructions that you have defined and take the temperature of the product once it’s cooked to prove that it’s hot enough. If you say that it’s ok for the consumer to cook from frozen, as well as cooking from chilled – make sure you’ve done trials on both scenarios and taken temperatures. If the product has to be cooked from raw – it is a really good idea to also send samples of the raw and cooked product away for micro testing, so you can prove that the cooking method makes the product safe. (The reason you send the raw sample away too is because you would generally expect the raw product to have bacteria there, whereas the cooked product shouldn’t – proving that the cooking worked.)
3. Shall be a process to verify that ingredient and allergen labelling is correct based on the product recipe and ingredient specifications
This section of the clause is talking specifically about the ingredient declaration and the allergen labelling (which for the UK, under the new FIR laws is written within the ingredient declaration).
You will need to prove that you have worked out the recipe, the quantities of each ingredient (and their individual components), then worked out the percentages and listed them in order. You will need show your workings (calculations) of this, and include %’s in the ingredient for items that are subject to QUID.
QUID – stands for QUantitative Ingredient Declaration – this is where you state the % of that ingredient(s) in the product.
There are a number of rules about when to apply QUID but generally they are:
- when the ingredient is listed in the legal name, title or descriptions
- when it is a characteristic of the product
- when special emphasis is on the ingredient(s) due to the use of words or pictures on the pack
Allergen information should also be documented and in the UK this means the allergens must be shown within the ingredient declaration. Again, this is not totally straight forward, there are number of rules that must be applied – if this is something that you would like me to provide more detail on (or any of the subjects discussed) please just let me know and I’ll try to include it in a future newsletter.
What the auditor will do
The end of the clause that says ‘and ingredient specifications’ (Shall be a process to verify that ingredient and allergen labelling is correct based on the product recipe and ingredient specifications.) is new to V7.
The auditor has now been asked by BRC as a minimum (although the application of this will probably vary from auditor to auditor) to check your printed packaging/ labelling and they will use your recipe and specifications to do this. They have been asked by BRC to check the recipe that you have on the agreed customer specification against the recipe that is being used in the factory (to make sure they match). They then need to check that the ingredient declaration order is correct by checking your calculations for the % of ingredients (including compounds) in the recipe and take into account processing losses. They will also check your QUID calculations and will ask you to prove how you make sure you stick to these QUID’s in practise in the factory – for example, if you are adding grated cheese to the top of a loaf of bread, how do you prove that you get the right amount of cheese on top?
In addition to the above, the auditor should also check to make sure that the text, pictures and other logos all meet the legislation – this is a massive, massive ask of the auditor. I’ve been working with labelling for many, many years and I have to admit I would find this difficult to do in the time provided without all my references/ books to hand that I use. Having spoken to some of the BRC auditors I know that they also feel the same, so only time will tell how much detail is applied during the audit to this clause. I would imagine though it would all depend on the knowledge of the auditor and what product groups they are most comfortable with. My advice would be to make sure that you have had your printed packaging checked by a third party and have this documented, so you can show the auditor.
Well I think we should break at this point (this has got far too long already!) – I’ll finish section 5.2 Product Labelling on the next newsletter.
I’d love to know your feedback on this newsletter – as my aim is to make it as useful to you as possible. Please let me know if you think it is too long, too short, doesn’t cover the bits you really want to know about – I’m honestly open to any feedback you have.
Also, if you have any specific labelling questions you would like to ask, or would like to comment or ask anything about the information in this newsletter please use the comments section below to get in touch or email us on firstname.lastname@example.org
The opinions expressed in this article are the author’s own and may not reflect the BRC Global Standards views. They are provided as a source of information, but we do not guarantee that adherence to them will ensure approval during an audit.