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

BRCGS Food Safety Issue 85.1 Product design/development
BRCGS Packaging Issue 65.1 Product development
BRCGS Agents & Brokers Issue 3
4.6 Product design/development
BRCGS Storage & Distribution Issue 410.3 Product design/development
FSSC22000 Version Product development
IFS Food Version 74.3.1 Product development
SQF Edition 92.3.1 Product Formulation and Realization

If the product development system doesn’t work, the product processed won’t meet the agreed specification and there’s a good chance that it won’t be safe. It also ensures that change control is applied effectively.

So, let’s go through what the Standards expect of a product development system.


There must be a procedure for the development, assessment and approval of new and existing products. The procedure must include:

  • The product development process steps that include project brief, hazard analysis, trials, product review and product approval.
  • Responsibilities at each step.
  • Customer requirements relating to design, development, specification, manufacture and distribution of the product.

Product developmentDocumentation must be collated during the development process, including:

  • Product development briefs.
  • Trial information.
  • Validation evidence.
  • Customer approvals.
  • Pack copy.
  • Artwork.
  • Specifications.
  • Approval samples and masters.

Where documents are kept in digital format, they must be:

  • Suitably protected to prevent loss.
  • Secure to prevent alteration by those who are unauthorised.


The responsibilities required to complete the product development process must be assigned to specific roles. Those who carry out these roles must be adequately trained.

Design requirements

All parties must agree, review and approve the product brief, to ensure that the product developed:

  • Meets the customer’s expectations.
  • Can be manufactured consistently to specification.
  • Meets the functional requirements of the customer and the final consumer.
  • Is legal.

The product brief must include:

  • A description of the product.
  • Any compositional requirements.
  • Quality, functional and safety parameters.
  • Any requirements for recycled materials.

The brief should be in place before the new product is progressed.

Control of hazards

Hazard ControlThere must be clear guidelines imposed on new product development, to control the introduction of hazards which would be unacceptable to the site or customers. For example, the hazards may be the introduction of glass containers or allergens.

The site must understand the product safety rationale and legal requirements for all new products. Any new product must be developed within these guidelines.

All new products and changes to existing products, packaging or methods of processing, must be formally approved by the Product Safety Team. This is to ensure that hazards have been assessed, and any suitable controls which have been identified through the hazard analysis system are implemented prior to trials.  The approval must be documented, even where no action is required.

Consideration must also be given to product safety requirements that require ongoing verification, such as any free from claims or functional requirements.

Sample approval

Product samples must be formally reviewed against the brief.

Where customer samples are to be kept, their requirements must be followed.

Customer-approved reference material or control samples of product, packaging, artwork or colour standards, must be controlled and stored to minimise degradation.

Product samples, artwork and associated processing equipment (e.g. plates, tooling/moulds) must be approved, prior to launch to confirm that the product meets the agreed specification.


Where new equipment is required, this must be clearly specified. The equipment must be commissioned and this must include incorporation into any relevant maintenance, foreign body and cleaning systems.

Processing trials

Processing trials must be carried out to validate that the product formulation and the process, to ensure that a consistent product can be produced, which meets the required specification.

There must be a set procedure or system which defines when trials are required. Trials of the full process may not be necessary but must meet their objectives – which is to validate any aspect that is new or has changed.

Where trials are not necessary, the justification for this must be documented.

Prior to trials taking place, the objectives of the trial must be agreed, including what samples are required.

Sufficient information from the trial must be collated during the trial, so that specifications can be developed. The records of the trial information and results must be kept as evidence.


Samples from trials must be used to validate that the product meets the agreed specification, this must include:

  • Shelf life – micro and sensory (flavour, colour, appearance).
  • Quality attributes.
  • Functional requirements.
  • Preparation and cooking instructions.

Preparation and cooking instructions

Cooking InstructionsYou need to formally document your cooking instruction trials. This means you need to document what times and temperatures the product has been cooked at, to achieve a safe product.

These trials should also be conducted in different appliances to make sure that variation of cooking is considered, such as gas, electric and fan ovens.

The time and temperature combination needs to achieve at least a pasteurisation cook, to make it safe to eat. And, the trials need to prove that this time and temperature combination was achieved. This may require data logging of the product, to prove that the product was held at the required temperature for the required amount of time.

The trials should always be carried out at worst-case as well. Which means where a time or temperature range is given to the customer, the lowest temperature and the shortest time should be used in the trials.

Consideration must also be given, where there is a potential for the customer to do something different with the product. For example, if the product can be barbequed, rather than cooked in a typical oven. The procedure for the cooking instructions trials and validation will need writing into the NPD procedures.

Samples of the cooked products will also need to be sent for lab testing to prove that they meet cooked micro standards. Make sure records of the cooking instruction trials and validations are retained for audit.

Shelf life validation

Shelf life validation must be carried out following documented protocols that consider:

  • Worst-case conditions (e.g. temperature) that the product is subjected to during processing, handling, distribution and where applicable – consumer handling.
  • Any rework, or work in progress materials used in the product that will affect shelf life.
  • Safety requirements for microbiological or chemical testing.
  • The use of quality attribute standards for sensory analysis.
  • A margin of safety, so that shelf life is validated to slightly beyond the intended life.
  • Sampling rules, e.g. start, middle and end, and the number of batches.
  • Recording of the method and results.

Where theoretical analysis is used to determine the shelf life of long life products, the theory and justification must be documented.

The validation must consider the criteria for ongoing verification, during the lifetime of the product.


The term protocol means a procedure or a set of rules. So, it’s basically a procedure for how you are going to do shelf life trials. This may seem very straight forward to begin with. “We get samples, we send them off  to the lab to be tested or we taste them over life.”  Easy – well, it needs to be a little more detailed than that.

Sampling rules

Are you producing a product that is ready-to-eat? If you are, then you may need to include rules around the number and types of samples. For example, for chilled ready-to-eat products, you may need to take three samples from three separate production runs, to ensure your samples consider any variation across different runs. For other products, you may just take three samples from one production run, but one sample from the beginning, one from the middle, and one from the end of the run. Then, you need to think about how the product would be handled after it’s produced.

Let’s take a bottle of milk as an example…

Some factory dispatch chillers are held at 3°C, so the product is held at 3°C until it’s dispatched. The product then goes into a 5°C chill chain, until it’s delivered to the store. When the product is purchased by the customer, the customer will typically keep the milk in the door of their fridge. A home fridge, especially in the door area, which is the warmest part, runs at about 8°C.

The protocol for testing the bottle of milk would need to consider all of the temperatures, and you need to define how long the milk is going to be held at each temperature.


  • One day at 3°C.
  • Two days at 5°C .
  • Remaining shelf life at 8°C.

This means, that you would have to hold the product at these temperatures and then send it to the lab to test at 8°C on day three.

Alternatively, you can send the samples to the lab and have a pre-agreed plan with them, to hold the product at the right temperatures for the right amount of time.

Once you have your conditions set for your testing, you then need to specify what testing you’re going to do. If you’re carrying out lab testing, the tests need to reflect the pathogen or hygiene indicators that you’ve defined in your HACCP.

Quality panel

If you have a product that doesn’t support pathogenic growth, you’ll need to specify what quality standards you need to achieve through the shelf life of the product. This may be sensory testing, or you may need to carry out mould testing if your product is susceptible to mould growth. You need to document the testing methods in your protocol. Then, as we’ve talked about previously, you need to then define what the acceptable limits are for the tests you’re doing. If you’re doing start of life and end of life testing, you’ll need to define the limits for both. Once you have your protocol documented, make sure you communicate it to those involved, not forgetting your lab.

Transit trials

Packaging must be designed to ensure that the product meets the specification. Transit trials must be carried out using worst-case scenarios to confirm this.

This validation must consider:

  • The distribution environment, taking outside temperature into account where this has an impact.
  • The different modes of distribution (e.g. road, sea).
  • Unit and SKU configuration and measurements (e.g. dimensions, weight).
  • Mixed load requirements.
  • Handling and storage requirements (e.g. leakage, damage).
  • Load plan requirements (including weight and minimum / maximum loads).
  • Re-usage of any component of the packaging system.
  • Product (e.g. tampers) and vehicle security (e.g. seals).
  • Legal requirements.

Obsolete items

We all know that obsolete packaging can at times hang around for quite a while, due to financial processes. We need to make sure that this obsolete packaging is effectively controlled, so it doesn’t make its way, by mistake back into use.

Where materials, artwork, printing equipment or packaging becomes obsolete, due to product life cycle or development, there must be a procedure in place to manage these items, to ensure that they don’t get used by mistake. The procedure must include:

  • A system to prevent accidental use of obsolete items.
  • A maximum timescale for disposal.
  • How obsolete items will be disposed of.
  • A process for rendering trademarked materials unusable.
As always, if you have any top tips you can share about product development, or you have any comments or questions, please get involved and share them below.
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