BRCGS Packaging Issue 7 Changes

In 2024 BRCGS announced that the Packaging Standard was under revision and an update to issue 7 was published on 28^th October 2024. External audits against issue 7 start in April 2025. Any certificates to issue 6 up until this date will remain valid. All certified companies will need to transition to issue 7 during their following audit. 167 clauses have been redeveloped and there is 1 additional clause. There is a heavy focus on intended use of the finished product and the use of risk assessments. Here is a summary of some of the changes:

Senior Management Commitment

1. Update to the statement of intent to provide an increase in focus on continual improvement to the organisations product safety, quality management, and the site’s product safety and quality culture.
2. 2 *NEW CLAUSES* 1.1.3 requirement for a confidential reporting system and 1.3.3 allocation of overall responsibility on site for the day-to-day management of the management system when external expertise is utilised.
3. 1.1.1 now requires the product safety and quality policy to include commitment to continuously improve the site’s product safety and quality culture.
4. 1.1.2 includes measures to achieve a positive culture change to provide a clear indication of specific topics which form part of a continual improvement plan.
5. 1.1.8 ensuring all requirements are in place so that unannounced audits can be undertaken in accordance with the updated audit protocol.
6. 1.1.9 requires there to be a member of senior management onsite and available during the audit to discuss the implementation of the product safety and quality culture plan.
7. 1.2.4 Personnel awareness to report risks or evidence of unsafe or out-of-specification product, equipment or raw materials.

Hazard Analysis and Risk Assessment (HARA or HACCP)

1. Section 2 the Hazard Analysis and Risk Assessment has been changed to expand 2.2’s requirement into clearly defined subclauses in line with the revised CODEX Alimentarius. This provides a logical framework to follow when implementing HACCP at the site.
2. There has been a change to the terminology of Critical Control Points (CCP’s) Critical Control Measures (CCM’s) to aid clarity within this section.

Management of Outsourced Processes

1. Clarification to the definition Outsourced Processes.
2. 3.9.1 Supplier Approval Process now includes the providers of outsourced processes.
3. Requirement to agree and document outsourced processes in service specifications and review within the sites HARA plan.

Traceability

1. 3.10.4 now requires a traceability test across the range of product groups that the site manufactures. With a record of the summary of the test completed and all supporting documents to demonstrate effective execution of the test.
2. Traceability test must now be conducted within 4 hours unless local legislation or customer requirements requires otherwise.

Allergen Management

1. Requirement to implement and maintain an allergen management plan, in cases where there is the potential of contamination from allergenic or intrinsic allergenic components identified during the HARA process.
2. The plan shall minimise or eliminate the risk of contamination to and/or from the product with labelling legal requirements for the country of sale also being met in this plan.

Other Key Changes

1. 3.14.2 requires the incident management procedure to provide guidance and instruction to relevant personnel regarding what type of event shall constitute an accident.
2. 3.14.6 *NEW CLAUSE* -the site to notify their certification body within 3 working days of a significant product safety or legality incident.
3. 4.2 introduces sub-sections to look at specific areas of the building fabric including walls, doors, ceilings and floors.
4. 4.3 considers the impact of utilities on the intended use of the product.
5. 4.4.1 provides greater guidance around product defence.
6. 4.6 requires the need for specifications prior to sourcing new or new-to-site equipment and risk-based commissioning.
7. 4.8.6 requires a review of the environmental monitoring programme in which the site shall review this at least annually unless there is a change in manufacturing conditions or consistently negative results.
8. Section 5 sees *6 NEW CLAUSES*
9. 5.4.6 requires a procedure for equipment failure.
10. 5.4.7 ensures that the product being manufactured conforms to legal or customer requirements with records being maintained.
11. 5.4.8 ensures that customer requirements for sample retention are identifiable and kept for a defined period.
12. 5.4.10 requires adequate control over products, materials or areas on site which are outside of scope.
13. 5.5.2 requires accuracy and control of measuring equipment in regard to the product parameters.
14. 5.6.2 requires validation of the inspection and testing procedure to ensure accuracy of results.
15. Sections 6 and 7 have seen minor changes. The majority of changes have been to align with other BRCGS Standards

Audit protocol now provides 3 options:

1. Announced – Full announced audit is conducted on the site with one audit in the 3-year cycle being unannounced.
2. Blended – Only available for sites who already have certification, the 3 year cycle consists of a remote audit on the documentation followed by an in-person site audit with one visit in the 3 year cycle being unannounced.
3. Unannounced – This is voluntary and consists of unannounced audit. There has also been a change to Lapsed Certificates.

That’s quite a few changes to take on! If you need help with your transition, please get in touch here.