BRC Packaging certification: achieving BRCGS Packaging Materials certification.

This standard governs product safety, quality, legality and compliance at a packaging manufacturing site, from the approval of raw materials through to the dispatch of finished products. It is most often required by industrial customers in the food, cosmetics and retail sectors.

Tracklab supports sites throughout this process: scoping the perimeter, gap analysis against the standard, structuring documentary evidence, preparing teams, mock audit and maintaining certification over time. Our platform centralises supplier and product data, automates document collection, tracks deadlines and uses AI (artificial intelligence) to exploit documents.

Tracklab is neither a certification body nor an ERP : the certificate is issued by an accredited body, and the engagement covers everything that is prepared before the audit and maintained afterwards.

In brief: key takeaways

• The applicable standard is BRCGS Packaging Materials Issue 7 ; audits have been conducted against this version since 28 April 2025. Always check the current issue with your certification body before preparing for the visit.
• The scope covers all types of packaging : paper and board, plastic, metal, glass, wood and composite materials, with requirements adjusted according to the hygiene risk (high or low).
• The audit covers the entire site, from receipt of raw materials to dispatch, and generally lasts 1.5 to 2.5 days of on-site audit depending on the size of the site and the number of HARA studies.
• The main causes of failure are documentary: incomplete declarations of compliance, untraced material composition, missing or expired supplier evidence.
• The Tracklab engagement produces a structured evidence file, a prioritised action plan and management of document deadlines - not simply support in drafting procedures.

The scope of the BRCGS Packaging Materials standard

The BRC Packaging standard applies to all packaging and packaging materials intended, directly or indirectly, for contact with food or sensitive products. It is recognised internationally and enables a site to demonstrate to its customers that it controls its risks.

Types of materials covered

The standard also applies to related activities: printing, cutting, assembly, gluing, secondary packing and integrated logistics where these operations form part of the declared scope.

Which sites are concerned

A site is concerned as soon as it manufactures, converts or assembles packaging intended for food or sensitive customers, and one of those customers - or a tender - requires certification. The certification scope is declared site by site and must describe precisely:

• products covered, with their intended uses;
• processes carried out on site;
• outsourced activities, which must still be controlled even if they are not certified;
• any excluded products, whose exclusion is exceptional, must be validated upstream and whose flows must be physically separated.

Packaging manufacturers will find useful additional information on our page dedicated to packaging sector challenges.

The link with food contact

The link with food contact is central, but it must not be confused with regulatory compliance. The BRCGS standard assesses a management system : hygiene, contamination control, traceability, supplier control, quality and safety culture. It does not replace the regulatory obligations applicable to food contact materials, in particular Regulation (EC) No 1935/2004 and, for plastics, Regulation (EU) No 10/2011 and the associated good manufacturing practices.

In other words: a BRCGS Packaging certificate attests that a site controls its processes, but does not on its own prove that a given packaging item is compliant for a given food use. The two forms of evidence are complementary and must be available in parallel during an audit or a customer review.

The scope of our support

Tracklab works on the preparation, structuring and maintenance of certification. We do not carry out the certification audit and do not issue certificates.

The scope of our support covers:

• Scoping the perimeter : definition of products, processes, outsourced activities and any exclusions to be validated with the certification body.
• Gap analysis between the site's documentary and operational situation and the requirements of the standard.
• Structuring the documentation system : specifications, declarations of compliance, risk analyses, supplier evidence, hygiene and traceability procedures.
• Collecting and securing evidence from raw material suppliers and service providers.
• Managing document deadlines (validity of certificates, analyses, declarations, annual reviews).
• Preparing teams : awareness-raising, preparation for audit interviews, mock audit.
• Maintenance after certification: document updates, change management, preparation for the renewal audit.

This engagement is the "packaging" version of our support offer for BRC certification. For sites that must meet several customer standards simultaneously, the logic of pooling evidence is described in our content on IFS and BRC Broker.

How the engagement unfolds, step by step

Step 1 - Scoping and qualifying the perimeter

An initial discussion defines the sites, products and processes concerned, the target issue of the standard and the chosen certification body. This step produces a scoping note that will serve as the reference for the rest of the engagement.

Step 2 - Document review and gap analysis

We review the evidence available: specifications, declarations of compliance, safety data sheets, supplier certificates, test reports, HARA studies (hazard analysis and risk assessment), internal procedures. Each requirement is compared with the reality of the site, with a priority level.

Step 3 - Prioritised action plan

The gap analysis is translated into an action plan: documentary actions, on-the-ground actions, owners, deadlines. Prioritisation distinguishes what is blocking for the audit from what can be addressed in the next cycle.

Step 4 - Structuring the documentation system

Most of the work consists of making evidence retrievable, complete and up to date. The Tracklab platform centralises supplier and product documents, indexes their content and makes it possible to check in a few clicks that a declaration of compliance does cover the material concerned and the correct intended use.

Step 5 - Mock audit and corrective actions

A mock audit, conducted in the same format as a real audit (document review, interviews, on-site observation), tests the robustness of the system and corrects the final gaps. This is the step that most often reveals inconsistencies between what is written and what is done.

Step 6 - Audit day and post-audit follow-up

We support the site during the certification audit, then during the handling of gaps and preparation for the next cycle. Maintenance then depends on consistency: tested traceability, annual review of withdrawal and recall procedures, monitoring of the validity of supplier evidence.

The deliverables of the engagement

These deliverables feed directly into the management of compliance documents and certifications in our compliance and certifications module.

Documentation requirements specific to Packaging

The standard is demanding on documentary evidence, often more so than on production itself. Here are the five areas to master as a priority.

Declarations of compliance

Each incoming material must be covered by a declaration of compliance appropriate to its intended use. For plastics, the written declaration required at stages other than retail must contain the information provided for by the regulations, identify the operator issuing it, specify the conditions of use and be kept up to date in the event of a substantial change. French regulatory guidance is summarised by the DGCCRF.

Point to watch: a generic "compliant material" declaration with no intended use, no conditions of use and no version does not protect the site during an audit.

Food contact

For each reference, it must be possible to demonstrate whether food contact is direct or indirect, which food types are concerned, and under what temperature and time conditions. Migration tests or supporting assessments must be retrievable at reference level, not only at material family level.

Material composition

The composition (layers, inks, adhesives, additives, laminating adhesives, recycled materials) must be known and traceable down to tier 2 suppliers where the risk justifies it. This requirement is in line with the transparency obligations set by European packaging regulation: our PPWR compliance guide details what this changes for manufacturers.

Traceability

Traceability must be tested regularly, across the entire flow - receipt, storage, processing, dispatch - and not only on finished products. The standard expects a withdrawal and recall procedure tested at least once a year, with the results and key timings recorded, followed by use of the lessons learned.

Raw material suppliers

Supplier approval, initial evaluation, performance monitoring and above all the validity of evidence (certificates, declarations, analyses) are a classic point of failure. Expired evidence on a critical raw material is enough to generate a non-conformity.

Common mistakes that cause a BRCGS Packaging audit to fail

1. An unclear scope. Products, processes and outsourced activities are described approximately, or exclusions are not validated with the certification body.
2. Expired supplier evidence. Out-of-date certificates or declarations, with no deadline tracking.
3. A declaration of compliance not linked to a use. The document exists, but it does not cover the material or the application concerned.
4. Incomplete composition. Knowledge of layers, inks and adhesives stops at tier 1.
5. Traceability tested only on paper. The upstream-downstream test is not carried out or is not documented.
6. A system that is written but not applied. The procedures exist, but the records on the ground are missing: this is the most visible gap during observation.
7. A single internal audit campaign per year. The standard expects several internal audits spread over the year, with corrective actions handled and verified.
8. A recall procedure that is never tested. The absence of a documented and quantified annual test is systematically raised.
9. Hazard analyses not updated. Any change of material, process or supplier must trigger a review.
10. A quality and safety culture that is hard to demonstrate. Management must be able to explain its objectives, its reviews and how feedback from the shop floor is handled.

Take action

Three concrete actions allow you to start straight away:

1. Clarify the scope. List the sites, products, processes and outsourced activities that are candidates for certification, and identify the exclusions under consideration.
2. Review the evidence. Make an inventory of declarations of compliance, supplier certificates and test reports, noting their validity date and the use they cover.
3. Identify at-risk deadlines. Any evidence expiring in the six months before the audit must be secured as a priority.

The engagement starts with a one-hour scoping discussion, based on the list of references and the documentation available. It confirms the scope, estimates the preparation workload and sets a realistic audit date.