BRCGS Packaging Materials System Requirements
Guidance Aligned with BRCGS Global Standard for Packaging & Packaging Materials
Published by Food Safety Systems | A Service by Consultare Inc. Group – A Compliance Company
Manufacturers and converters of food packaging must ensure materials meet stringent safety, quality, and compliance requirements. The BRCGS Packaging Standard helps organizations demonstrate due diligence, meet retailer expectations, and comply with global food contact regulations.
This guide provides a practical checklist to implement certification-ready systems for packaging manufacturers, covering all critical aspects of the BRCGS Packaging Standard.
BRCGS Packaging Compliance Checklist
1. Leadership Commitment (Clause 1)
✓ Document a product safety policy signed by senior management
✓ Conduct annual management reviews of packaging safety systems
✓ Allocate resources for compliance and continuous improvement
2. Hazard & Risk Analysis (Clause 2)
✓ Implement a HACCP-based risk assessment for packaging materials
✓ Identify hazards (chemical migration, physical contaminants, etc.)
✓ Validate control measures for critical processes
3. Quality & Food Safety Management (Clause 3)
✓ Maintain documented procedures for all operational controls
✓ Establish specifications for raw materials and finished packaging
✓ Implement traceability systems (one-up, one-down)
4. Site & Facility Standards (Clause 4)
✓ Maintain hygienic production areas to prevent contamination
✓ Control pest management with licensed contractors
✓ Segregate non-food grade materials
5. Product Control (Clause 5)
✓ Verify raw material compliance (e.g., FDA, EU 10/2011)
✓ Conduct migration testing where required
✓ Ensure inks, adhesives, and coatings are food-safe
6. Process Control (Clause 6)
✓ Calibrate and maintain converting/printing equipment
✓ Monitor critical control points (CCPs) (e.g., temperature, curing)
✓ Control rework materials to prevent contamination
7. Personnel Training (Clause 7)
✓ Train staff on GMPs, hygiene, and food contact safety
✓ Restrict access to production areas
✓ Maintain training records with competency assessments
8. Supplier & Raw Material Approval (Clause 8)
✓ Risk-assess suppliers (prefer BRCGS-certified vendors)
✓ Require Declarations of Compliance (DoC) for all materials
✓ Conduct supplier audits for high-risk inputs
9. Testing & Compliance Verification (Clause 9)
✓ Establish testing protocols for food contact suitability
✓ Maintain certificates of analysis (CoA) for critical materials
✓ Validate barrier properties (if applicable)
10. Incident Management & Recall (Clause 10)
✓ Document a recall procedure with customer notification steps
✓ Conduct mock recalls annually
✓ Maintain batch/lot traceability records
11. Food Fraud & Defense (Clause 11)
✓ Conduct vulnerability assessments for packaging materials
✓ Implement tamper-evident features where required
✓ Secure facilities against unauthorized access
12. Internal Audits & Continuous Improvement (Clause 12)
✓ Audit all BRCGS clauses annually
✓ Implement corrective actions with root cause analysis
Support for BRCGS Packaging Certification
We provide tailored solutions for packaging manufacturers:
Documentation Tools
• BRCGS-compliant HACCP templates
• Supplier approval questionnaires
• Internal audit checklists
Implementation Support
• Gap assessments & pre-audit reviews
• Food contact regulatory guidance
• Mock recall simulations
Testing & Validation
• Migration testing protocols
• Lab partnership referrals
• Compliance documentation review
Ready for BRCGS Packaging Certification?
Let us help you build a system that’s efficient, auditable, and globally aligned.
Schedule a Pre-Audit Consultation
Request Sample Documentation Kit
Reference Note
This content aligns with the BRCGS Global Standard for Packaging & Packaging Materials. For full certification requirements, refer to the official standard at www.brcgs.com.
Disclaimer
Food Safety Systems is an independent consultancy and not affiliated with BRCGS. Always validate compliance with food contact regulations.
