Product Labeling
Aligned with BRCGS Food Safety Issue 9 – Clause 5.2: Product Labelling and Pack Control
Requirement Overview
BRCGS Clause 5.2 requires sites to ensure that all product labels are accurate, approved, and correctly applied to protect consumers and meet legal, regulatory, and customer-specific requirements.
Clause 5.2.1: “There shall be a process to verify that labelling and pack information is correct.”
Clause 5.2.2: “Label verification shall include checks to ensure that all legislative, allergen, and customer requirements are met.”
Incorrect labeling—especially related to allergens or claims—is a critical risk that can lead to product recalls, consumer harm, and non-conformances during audits.
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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✓ Verify that all product labels meet legal and customer requirements
✓ Prevent the use of incorrect, outdated, or unauthorized labels
✓ Ensure label accuracy for allergens, ingredients, and claims
✓ Maintain records of approval and verification
Step-by-Step Compliance Implementation
1. Establish Label Verification and Approval Procedures
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Procedure Should Include:
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• Pre-approval of all label designs and content
• Checks for regulatory, allergen, and customer-specific compliance
• Clear roles and responsibilities for label review and sign-off
Evidence to Maintain:
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• Label approval records with reviewer signatures
• Regulatory and customer requirement checklists
• Current label database or register
- • Pre-approval of all label designs and content • Checks for regulatory, allergen, and customer-specific compliance • Clear roles and responsibilities for label review and sign-off
- • Label approval records with reviewer signatures • Regulatory and customer requirement checklists • Current label database or register
2. Control Label Storage and Usage
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Best Practices Include:
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• Secure storage of printed labels
• Issuance of labels only for approved production runs
• Obsolete labels removed from production areas
Evidence to Maintain:
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• Label issue logs
• Label inventory and control records
• Obsolete label disposal documentation
- • Secure storage of printed labels • Issuance of labels only for approved production runs • Obsolete labels removed from production areas
- • Label issue logs • Label inventory and control records • Obsolete label disposal documentation
3. Conduct Pre-Production Label Checks
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Checks Must Include:
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• Correct label applied to correct product
• Right product name, ingredient list, allergen declarations, net weight, and date code
• Match to customer specifications and regulatory requirements
Evidence to Maintain:
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• Line start-up check records
• Label verification forms
• Label samples signed by QA or production leads
- • Correct label applied to correct product • Right product name, ingredient list, allergen declarations, net weight, and date code • Match to customer specifications and regulatory requirements
- • Line start-up check records • Label verification forms • Label samples signed by QA or production leads
4. Monitor Label Accuracy During Production
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Monitoring Includes:
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• In-line checks for label application, positioning, and legibility
• Verification of batch codes, barcodes, expiry dates, and claims
• Random sampling and visual inspections
Evidence to Maintain:
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• Label verification logs per production shift
• Line inspection reports
• Non-conformance reports (if applicable)
- • In-line checks for label application, positioning, and legibility • Verification of batch codes, barcodes, expiry dates, and claims • Random sampling and visual inspections
- • Label verification logs per production shift • Line inspection reports • Non-conformance reports (if applicable)
5. Address Non-Conformances and Prevent Recurrence
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Required Actions:
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• Isolate mislabeled products
• Conduct root cause analysis
• Apply corrective/preventive measures
Evidence to Maintain:
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• Non-conformance and incident reports
• CAPA records
• Label re-training logs for affected staff
- • Isolate mislabeled products • Conduct root cause analysis • Apply corrective/preventive measures
- • Non-conformance and incident reports • CAPA records • Label re-training logs for affected staff
Common Audit Findings & Recommended Fixes
| Audit Finding | Recommended Action |
|---|---|
| Incorrect allergen declaration | Implement stricter label sign-off and allergen validation checks |
| Outdated label used in production | Remove all obsolete labels from inventory and update document control |
| No evidence of label verification | Use label checklists and maintain signed verification forms |
| Unauthorized label change | Enforce a documented label change control process |