We recently hosted an insightful webinar session on 'Issue 7 – One Year On', where our colleagues Gwenda Jarrett (Programme Manager – Global Non-Food Standards) and Andrew Dalgleish (Technical Manager – Packaging Materials and Consumer Products) provided an update on the transition period and dived into the key themes and trends observed in non-conformities so far.
During the live webinar, we received many technical questions, and our speakers have compiled and answered all of them below.
Issue 7 questions
1. Is there any plan for an Interpretation Guideline for the HAVI bolt on?
The HAVI/tms module already includes the interpretation of each clause, meaning there is no requirement for a further standalone document.
2. Is a Mock Recall required in Issue 7? I know a traceability exercise is required.
Yes, it is mandatory under clause 3.14.5. The clause stipulates that the incident management procedure relating to product recall/withdrawal must be tested, at least annually, in a way that ensures its effective operation.
Results of the test must be retained and include the timings of key activities. Crucially, the results of the test, alongside any actual incidents, must be used to review the procedure and implement necessary improvements.
3. Is a manufacture traceability report required, or is a statement showing the actual traceability exercise was conducted sufficient?
The Interpretation Guide provides highly useful guidance on this specific point.
Verification of traceability systems at a supplier site can be successfully achieved through one or a combination of the following methods:
- Testing the raw material supplier’s traceability: For instance, as part of your site’s own traceability test, you can send batch details of a raw material to the supplier. The supplier then completes a traceability test for that batch and returns the records to your site.
- A worked example: A documented scenario sent from the supplier that clearly explains their internal traceability process.
- A detailed description: A comprehensive overview of the traceability system provided directly by the raw material supplier.
4. For plastic resin, do we need to have the broker certified as well?
The Standard does not explicitly require a broker to be certified. However, utilising a certified broker significantly simplifies your supplier approval process.
For example, under clause 3.6.6, less documentation is required on file if the broker holds a GFSI-certified status. Clause 3.6.2 outlines four distinct pathways for approving a broker, and GFSI certification is just one of those options.
5. Is it correct that traded goods should not be included in segregation rules? Should traded products be stored physically segregated, or can they be stored completely segregated within the same warehouse?
The approach to both questions depends entirely on a robust risk assessment, which must be completed by the site trading the goods.
For instance, if you are manufacturing blow-moulded bottles and you trade the caps for those specific bottles, they will be used together by your end customer and shipped together; therefore, there is no perceivable risk from storing them together.
Conversely, if you are manufacturing packaging for baby food but trading bags of adhesive granules for general use, there is a distinct, perceivable risk. If those adhesive bags are stored above the baby food packaging and a spill occurs due to damage, granules could enter the consumer packaging. In this scenario, your risk assessment would direct you to store the items separately.
If these traded goods are excluded from the scope of your audit, several clauses potentially apply, including 5.8.5 and 2.5.2, the Interpretation Guideline for clause 7.1, and Section 1.6.2 of the Protocol. These dictate that excluded items must not present any risk to the products remaining within the audit scope. Your risk assessment must clearly demonstrate either that no risk exists (requiring no further action) or identify the risks and establish the necessary control measures to mitigate them.
6. What if finished goods occasionally return to our warehouse for storage with no rework, or return for rework before shipping, but sometimes ship directly to the customer? We documented both options in the HARA, but would one be classified as a service and the other as outsourced? It is the same process and vendor, just a different shipping route.
Your understanding is correct. If the material returns to your site (the site undergoing the audit) for any reason, the vendor is executing an outsourced process. However, if the material does not return to your facility and goes straight to the customer, the vendor is acting as a service supplier.
You should clearly map out all potential operational options within your HARA process flow. When assessing and approving the vendor in this scenario, you must consider the requirements for both categories (outsourced processor and service supplier) and ensure compliance criteria for both are fully met.
7. Is it required to trace pallets, plastic strapping, and stretch film?
Typically, items such as standard pallets, plastic strapping, and stretch film are classified as disposable or tertiary packaging. Consequently, they do not require tracing in the same rigorous manner as primary and secondary packaging items.
However, exceptions do apply. In many instances, a customer may enforce specific requirements that exceed the baseline requirements of the Standard, which you must meet. Additionally, many packaging producers now utilise reusable crates, bulk containers, or pallet boxes to ship products to customers. These items must be risk assessed to determine if a traceability requirement is necessary. If the identified risk impacts product safety, they must be integrated into your traceability system. If the tracking need is driven solely by the financial cost of the shipping containers, traceability is not required under the Standard.
8. Do I need to perform a traceability test if a supplier is already GFSI certified?
The brief answer is no, unless your specific customer explicitly mandates it. All GFSI-benchmarked schemes inherently include robust traceability as a core requirement. Therefore, a traceability test will have already been successfully evaluated during their independent GFSI audit, meaning you do not need to replicate this exercise to satisfy BRCGS Standard requirements. The obligation to conduct a traceability test, or maintain active evidence of the supplier’s internal traceability system on file, applies solely to suppliers who are not GFSI certified.
9. Can we see the write-ups for the major non-conformities addressed? i.e. what specifically was lacking within the traceability process.
To maintain strict client confidentiality, we are unable to share specific audit findings or exact data points from individual site reports.
10. If the Declaration of Compliance (DoC) content lacks sufficient details (missing mandatory regulation items, etc.), what is the ideal grading considering it is also a legal requirement?
If an audit reveals insufficient information to demonstrate full conformance, the auditor will evaluate the issue using the standard non-conformity definitions outlined in the Standard. This allows them to accurately determine the appropriate level of non-conformity to raise.
BRCGS and individual Certification Bodies provide comprehensive training to support auditors in making these technical evaluations. If an auditor is ever in doubt, they are advised to consult their Certification Body for direct guidance.
11. Why does the unannounced audit have a four-month window?
The unannounced audit window is set to a four-month period prior to the re-audit due date.
This timeframe allows the Certification Body sufficient operational flexibility to select an appropriate date to visit the facility. The objective is to ensure the audit occurs while the site is fully operational, without providing the site with prior knowledge of the exact date.
12. Do the BRCGS standards on packaging include Packaging Waste and the Deposit Refund Scheme?
At present, Packaging Materials Issue 7 addresses comprehensive waste and disposal requirements under clause 4.10.
Because BRCGS is a global standard, it does not explicitly outline country- or region-specific legislative schemes. Instead, it requires the individual site to understand, apply, and demonstrate compliance with all relevant local legal obligations to the auditor, who will be well-versed in local requirements.
Watch on-demand
You can access the full recording of the webinar and download the accompanying resources on our website.
Contact us
Please get in touch with our team if you have any further questions.