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

BRCGS Food Safety Issue 85.5 Product packaging
BRCGS Packaging Issue 63.4.3 Statement of compliance
BRCGS Agents & Brokers Issue 3
BRCGS Storage & Distribution Issue 4None
FSSC22000 Version 5.1FSSC 22000 2.5.11(a) and ISO 22000:2018 characteristics of packaging and functional effect on food
IFS Food Version 74.5 Product packaging
SQF Edition Verification of packaging

Designing and sourcing packaging that’s fit for purpose is a key aspect to producing a safe, legal, authentic and quality product that meets the specification.

Packaging design

The packaging and dispatch pack configuration, must be designed to:

  • Meet the finished product specification.
  • Meet any functional requirements.
  • Be suitable for the application of use.
  • Not pose a risk of contamination (e.g. in-process packaging must be of sufficient gauge and colour).

Functional packaging

All packaging has a function, but some packaging has functionality that controls the safety of the product. For example, if you’re using modified atmosphere packing, or vacuum packing, the film you use will have specific properties – that stop the gas getting out, or air getting in.

It’s therefore important that these functional requirements are clearly stated on the specification of the packaging – so that both the supplier and the user of the packaging know what it’s being used for.

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Application of use

When sourcing packaging, how it will be used must be assessed, to ensure that the packaging is suitable. For example, that it’s suitable for:

  • Hot filling.
  • Freezing.
  • Suitable for oven or microwave.
  • Any compositional characteristics such as high fat or pH.
  • Modified atmosphere packing.
  • Storage and distribution conditions.

It’s the responsibility of the supplier to provide this information and the user of the packaging, to check it’s suitable for use in their specific application.

Dispatch configuration

This is the format in which the product is dispatched. For example, if it’s going out on a pallet, then the pallet will have a configuration of:

  • How many boxes are on each layer.
  • How many layers there are on a pallet.
  • How the boxes are arranged.

The boxes will be arranged in a specific way to make the pallet as sturdy as possible. Therefore, it’s important that this configuration is designed and followed.

Design validation

Packaging must be validated under worst-case situations, to prove that it does what it should. This may include assessment of:

  • Transit trial results.
  • Product assessment results (e.g. for functional requirement).
  • Assessment of packaging specifications and statements of compliance.
  • An up-to-date schematic diagram of the packaging system with key safety control points.
  • Specification and instructions for use of any cooling media.
  • Product-loading arrangement.

The validation must be reviewed:

  • At least annually.
  • When there are any changes.
  • Following a recall or withdrawal that’s linked to the packaging.

Statement of compliance

For packaging supplied, documentation must be available which provides the following details:

  • A statement that the packaging is suitable for food use.
  • The materials used in the manufacture of the packaging.
  • Confirmation that the packaging meets relevant legal requirements.
  • Results of migration tests.
  • The inclusion of any post-consumer recycled materials.
  • The intended application of the packaging and any limitations of use, e.g. temperature ranges.
  • The useable life of the packaging, for biodegradable packaging.
  • A list of the pieces of legislation that the packaging has been designed to comply with.
  • Date of issue of the document and if needed, an expiry date.

It’s the responsibility of the supplier to ensure that the documentation is accurate and kept up-to-date. This means that it must be compiled by a competent person. The supplier must review the statement of compliance at a frequency based on risk. Evidence of the review must be recorded.

Not all the responsibility lies with the supplier though, the customer (user of the packaging) also has a responsibility to ensure that they’ve received the documentation and reviewed it. The statement of compliance will include information about migration for example. And the migration tests will have been carried out under set conditions, which are in line with the application of the packaging. So, if the user of the packaging uses the packaging for a different application, then the migration results may not be valid for that application.

Packaging terms

Typically, we use the following terms when referring to packaging:

  • Primary packaging
  • Secondary packaging
  • Tertiary packaging



Reference: BRCGS Food Safety – Issue 8

“The packaging that constitutes the unit of sale to the consumer or customer (e.g. bole, closure and label of a retail pack or a raw material bulk container).”

Reference: BRCGS Packaging – Issue 6

“That packaging which constitutes the unit of sale, used and disposed of by the consumer (e.g. bottle, closure and label).”

Reference: BRCGS Agents & Brokers – Issue 2

“Packaging that is in direct contact with food.”

Reference: IFS Food – Version 7

“The primary packaging material fulfils one or more of the following conditions:

  • it is in contact and / or intended to be in contact with food
  • it can transfer their constituents to the food, and, if removed, the quality, safety and legality of its content is affected
  • it is part of the consumer unit.”



When BRCGS Food Safety was updated to Issue 8 the definition of primary packaging was changed to that above.

Up until that point, it was understood that primary packaging was the packaging that came into contact with the product. Secondary, was the next layer of packaging, such as the label or retail carton for example. The tertiary was generally the palletisation packaging – that type of thing.

The new definition of primary packaging confused matters – as a customer unit could include primary, secondary and tertiary packaging.


Clarification from BRCGS

BRCGS have clarified that the pallet and the shrink wrap would not be considered primary packaging.

Does it matter?

Well yes – because you have to carry out supplier approval on all primary packaging materials. So, extending the scope of primary packaging means that more types of packaging need to be approved.

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