Ensuring that your product meets the legal labelling requirements

Contents

• The standards
• The requirements
• BRCGS Food Safety Issue 9

The standards

This article is written to meet the following sections of the Standards:

The requirements

Information sources

All products must adhere to legal requirements:

• For the designated country of use,
• include information to allow the safe handling, display, storage, preparation and use of the product.

Both labels and specifications must be legally compliant.

The site must have a process in place to ensure that they are kept up to date with legal requirements, in the countries in which their product is used. This can be achieved through trade association memberships or industry subscriptions.

Legal sign off

There must be a procedure to check that the products are legally compliant, including:

• Ingredient declarations.
• Composition.
• Allergen information.
• Migration data.
• Product claims.
• Quantity and volumes.
• Safe handling and directions for use.
• Warning labels.
• Country of origin.

This applies to information stated on packaging, specifications or online.

Checks for correct allergen labelling must be included within new packaging sign off procedures e.g. 2D bar code must be updated for any packaging change to effectively manage packaging version control on sites.

Responsibilities “The company is responsible for completing the legal sign off checks. Except, where the checks are performed by:

• A third-party, and this is agreed in the third-party contract.
• The customer, and this is agreed in the customer contract.
• The customer for customer branded product, and therefore, it’s accepted that the customer is responsible for legal labelling.

Customer-specific requirements

Where the customer has specific requirements or rules for labelling (including completion of customer format specifications) there must be a procedure that details:

• What the requirements or rules are.
• How the requirements are addressed including responsibilities.
• How the requirements are verified.

Trademarks

Where the manufacturer’s trademarks or logo is applied to packaging materials of customers products, this must be formally agreed between the relevant parties.

First deliveries

When a change is made to printed packaging, goods-in staff must check that the correct version of the packaging has been delivered.

This should include checking the version number of the packaging against a master artwork reference.

As a minimum, this check must occur on the first delivery of an updated version of printed packaging. This check mut be formally recorded.

BRCGS Food Safety Issue 9

5.2.1 A procedure is now needed for artwork approval.

An addition to the interpretation regarding customer branded products has been made to ensure that the accountability for artwork approval is clear.

5.2.3 Clarity has been added that this process could be completed by a second party, as well as a third party. This means that this clause applies to both specification technologies and artwork houses contracted by your business or contracted by the customer.

Further clarity has been provided regarding the accountability for cooking instructions – the site must remain accountable even where the activity is carried out by another party.

9.6.1 This clause has been expanded to clarify that the procedure must include how traceability of traded products is maintained.

An addition to the interpretation of this clause now clarifies that the traceability procedure must manage the traceability of traded products.

9.3.3 Authenticity has been added to this clause.

3.5.2.2 Additional text has been added to the interpretation, but it doesn’t change the expectations of the clause.