Product Control: Product Claims & Traceability
Aligned with BRCGS Food Safety Issue 9 – Clauses 5.2 & 5.9
Requirement Overview
BRCGS Food Safety Issue 9 requires that all product claims be substantiated and compliant with regulations, and that a robust traceability system be maintained for ingredient, packaging, and finished product movements.
Clause 5.2.1: “Where a product is labelled or claims to be suitable for specific groups of consumers or meets certain conditions (e.g., allergen-free, gluten-free, organic), the basis for the claim shall be documented and substantiated.”
Clause 5.9.1: “The site shall have a system to trace product by unique lot identification from raw material to finished product and vice versa.”
Accurate claims protect consumers and brands. Traceability ensures your site can identify and act on food safety risks quickly and confidently.
Aligned with BRCGS for Storage & Distribution Issue 4 – Clause 4.3.1 & 4.3.3
Requirement Overview
BRCGS for Storage & Distribution requires that products moved via cross-docking are traceable and controlled at all times, even when they are not held in storage for extended periods.
Clause 4.3.1: “The company shall ensure that traceability is maintained at all stages, including during cross-docking operations.”
Clause 4.3.3: “Procedures shall be in place to ensure that all products handled, including those not stored on-site, remain under control and are not subject to contamination or substitution.”
Cross-docking operations must not compromise product traceability, safety, or integrity. Even with minimal handling and temporary presence, each product must be accurately identified, documented, and protected.
Key Compliance Objectives
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✓ Ensure all on-pack and off-pack claims are truthful and validated
✓ Maintain full traceability of ingredients, packaging, and finished goods
✓ Enable timely product recall, withdrawal, and root cause analysis
✓ Provide accurate, legible, and accessible traceability records for audits
Step-by-Step Compliance Implementation
1. Control and Validate Product Claims
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Examples of Common Claims:
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• Allergen-free (e.g., "gluten-free," "nut-free")
• Ethical (e.g., "free range," "fair trade")
• Nutritional (e.g., "high protein," "low sugar")
• Regulatory (e.g., "organic," "non-GMO")
Action Steps:
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• Maintain supporting documents and certifications for each claim
• Review regulatory guidance (FDA, EU, etc.) to ensure legal compliance
• Validate test data or supplier declarations annually
Evidence to Maintain:
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• Product claim register
• Certificates of analysis or declarations
• Claim approval forms and review records
- • Allergen-free (e.g., "gluten-free," "nut-free") • Ethical (e.g., "free range," "fair trade") • Nutritional (e.g., "high protein," "low sugar") • Regulatory (e.g., "organic," "non-GMO")
- • Maintain supporting documents and certifications for each claim • Review regulatory guidance (FDA, EU, etc.) to ensure legal compliance • Validate test data or supplier declarations annually
- • Product claim register • Certificates of analysis or declarations • Claim approval forms and review records
2. Implement End-to-End Traceability
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Traceability Scope:
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• Raw materials and ingredients
• Primary and secondary packaging
• Work-in-progress (WIP) and finished products
• Dispatch, distribution, and customer level tracking
Action Steps:
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• Assign unique batch or lot codes
• Link all materials and finished goods to those codes
• Map one step forward and one step back in the supply chain
Evidence to Maintain:
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• Lot code generation procedures
• Material intake logs and production records
• Finished goods dispatch records
- • Raw materials and ingredients • Primary and secondary packaging • Work-in-progress (WIP) and finished products • Dispatch, distribution, and customer level tracking
- • Assign unique batch or lot codes • Link all materials and finished goods to those codes • Map one step forward and one step back in the supply chain
- • Lot code generation procedures • Material intake logs and production records • Finished goods dispatch records
3. Conduct Traceability Testing
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Test Frequency:
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• At least annually (or as required by customer or certification body)
Test Process:
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• Select a finished product and trace back to all components
• Trace forward to distribution or customer level
• Complete test within 4 hours (BRCGS benchmark)
Evidence to Maintain:
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• Traceability test reports
• Response time tracking
• Corrective actions for gaps identified
- • At least annually (or as required by customer or certification body)
- • Select a finished product and trace back to all components • Trace forward to distribution or customer level • Complete test within 4 hours (BRCGS benchmark)
- • Traceability test reports • Response time tracking • Corrective actions for gaps identified
4. Integrate with Product Release & Recall Systems
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Cross-functional Integration:
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• Ensure traceability links to QA release protocols
• Align with mock recall, withdrawal, and complaint management
• Include all private label or branded variations
Evidence to Maintain:
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• Product release logs
• Complaint and recall cross-references
• Internal audit reports on traceability system effectiveness
- • Ensure traceability links to QA release protocols • Align with mock recall, withdrawal, and complaint management • Include all private label or branded variations
- • Product release logs • Complaint and recall cross-references • Internal audit reports on traceability system effectiveness
Common Audit Findings & Recommended Fixes
| Audit Finding | Recommended Action |
|---|---|
| Unsupported product claims | Maintain up-to-date claim documentation and certifications |
| Incomplete traceability records | Standardize log sheets and tracking software |
| Failure to trace back within required time | Conduct traceability drills and correct documentation errors |
| Packaging not linked to finished goods | Include packaging codes in batch tracking and inventory systems |