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traded products

Since the new issue of the Standard has been released, there has been some confusion with regard to whether you can use the BRC logo, if you exclude traded products from the scope of your audit.

In this article, we’ve got to the bottom of this and we can clear up the confusion!

The confusion…

The BRC Food Standard, in section 1.6 of the General Protocol states:

“The BRC Global Standards logo can only be used by sites that have no exclusions. The exclusion of products produced at a site will only be acceptable where:

  • the excluded products can be clearly differentiated from products within scope, and
  • the products are produced in a physically segregated area of the factory.

Where exclusions are requested, these shall be agreed with the certification body in advance of the audit. Exclusions shall be clearly stated on the audit report and certificate and the justification recorded on the audit report.

The certification of products must include an audit of the entire process from raw materials to end-product dispatch. It is not possible to exclude either parts of the process undertaken at the site or parts of the Standard. Where exclusions are accepted, the auditor shall assess any hazards presented by excluded areas or products (e.g. the introduction of allergens or foreign-body risks) and non-conformities may be raised relating to the excluded area where this poses a risk to the products within the audit scope.

Products purchased for resale by a site (i.e. traded products) can form an agreed exclusion and therefore the requirements of section 9 will not be applicable. It should be noted that the BRC Global Standards ‘food’ logo cannot be used for promoting traded products even when they form part of the certificated scope.”

The above protocol issued by BRC implies two things:

  1. That you can’t use the logo if you exclude anything from the scope of your audit
  2. It is acceptable to exclude traded products from the scope of your audit

Therefore, it reads as if – if you exclude traded products you can’t use the logo. However, The F835: Guidance on completion of Audit report, version 2, states:

“Note the BRC Global Standards logo can only be used by sites that have no exclusions.

The traded products section is now included in the main standard. Sites may choose to include or exclude Traded products within their audit. If a site acts as a trader of products not manufactured at the site, but does not want this to be included within the scope then this must be listed as an exclusion from scope. Note sites that have excluded Traded products may still use the logo.”

Clarification

We have now checked with BRC and they have confirmed that:

“We do allow the use of the logo by sites that are certificated to the Food Standard even when they choose not to include traded goods within their scopes. We would obviously be concerned if they were using the logo specifically in connection with the traded goods as this would be misleading for their customers.”

Conclusion

So, you can use the logo even if you exclude traded products from the scope of your audit. But, you must request that it’s ok to use the logo from BRC, by using this form: http://logo.brcdirectory.com/
You must also not use the logo to advertise traded products, even if you include them in the scope of your audit.

We hope that helps to clear up the confusion. BRC are aware that this is confusing, so hopefully they will clarify this formally in the F837 Position Statement for Issue 8 Food.

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