In Part 6 of the BRCGS Issue 9 series, we discuss the major changes under Requirement 6 (Process Control).
The Process Control requirement consists of 4 clauses (sections) and has 2 fundamental requirements.
The following clause is a fundamental requirement:
6.1 Control of operations
6.2 Labelling and pack control
A complete list of the clauses under Requirement 6 (Process Control). The clauses marked with * are discussed in this article:
6.1 Control of operations*
6.2 Labelling and pack control*
6.3 Quantity – weight, volume and number control*
6.4 Calibration and control of measuring and monitoring devices
6.1 Control of Operations
Clause 6.1.1 – Addition of “process specifications”
Clause 6.1 remains a fundamental requirement relating to the CONTROL OF OPERATIONS.
The fundamental statement of intent under Clause 6.1 and the requirements under Clause 6.1.1 now also refer to “process specifications” in addition to procedures and work instructions.
This means process specifications and work instructions should be separate documents or separate processes that should be implemented for all the items listed under Clause 6.1.1.
The second change is the addition of “storage conditions” to the list of things that require process specifications and work instructions or procedures.
The last change is the addition of a requirement to review process specifications, work instructions and procedures prior to changes that may affect food safety, legality and quality.
Clause 6.1.7 – Products or materials outside the scope of the audit
Clause 6.1.7 is a new clause under Clause 6.1 and it reads as follows:
“Where a site handles products or materials (e.g. by-products from production processes) that are outside the scope of the audit, these shall be controlled to ensure that they do not create a product safety, authenticity or legality risk to products within the scope.”
6.2 Labelling and Pack Control
Clause 6.2.1 – Processes for label use
Clause 6.2 remains a fundamental requirement relating to LABELLING AND PACK CONTROL.
There is an addition under Clause 6.2.1 and it reads as follows:
“Processes shall be in place to check label use is reconciled with expected use and the cause of any inconsistencies investigated.”
Clause 6.2.2 – Addition of “printed packaging and labels”
There is an addition of “printed packaging and labels” to Clause 6.2.2. It reads as follows:
“Documented checks shall be carried out at product changes to ensure that all products and printed packaging and labels from the previous production have been removed from the line before changing to the next production.”
Clause 6.2.3 – Clarifying the required checks during packing runs
Clause 6.2.3 now clarifies how the checks during packing runs should be done by providing the following example:
“at predefined intervals and when printed packaging or labels are brought to the line during the production run.”
6.3 Quantity – Weight, Volume and Number Control
Clause 6.3.2 – Where product quantities are not governed by legislation
In Clause 6.3.2 the term “must” have been replaced with “SHALL’. The requirement reads as follows:
“Where the quantity of the product is not governed by legislative requirements, the product shall conform to customer requirements and records shall be maintained.”
Clause 6.3.3 – Processes for handling rejected packs
Under Clause 6.3.3 there is the addition of “processes for handling rejected packs” to the list of minimum requirements for the procedures for the operation and testing of online weighers.
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Key facts
- Part 6 of ASC's BRCGS Issue 9 series covers Requirement 6 (Process Control), which spans four clauses, with 6.1 Control of Operations and 6.2 Labelling and Pack Control designated as fundamental requirements.
- Clause 6.1.1 now references process specifications alongside procedures and work instructions as separate documents, adds storage conditions to controlled items, and requires reviewing these before changes affecting food safety, legality or quality.
- New clause 6.1.7 requires that products or materials outside the audit scope are controlled to prevent safety, authenticity or legality risks.
- Clause 6.2.1 introduces label reconciliation, requiring processes to check label use against expected use and investigate any inconsistencies.
- Clauses 6.2.2 and 6.2.3 add 'printed packaging and labels' terminology to change procedures and require packing-run checks at predefined intervals and when new printed packaging or labels arrive during production.
- Clauses 6.3.2 and 6.3.3 strengthen language and add processes for handling rejected packs to online weigher procedures.
Frequently asked questions
What does Requirement 6 (Process Control) cover in BRCGS Issue 9?
Requirement 6 covers Process Control and spans four clauses in BRCGS Issue 9. Two are fundamental requirements: 6.1 Control of Operations and 6.2 Labelling and Pack Control. The other two are 6.3 Quantity (Weight, Volume and Number Control) and 6.4 Calibration and Control of Measuring and Monitoring Devices.
What changed in clause 6.1.1 for control of operations?
Clause 6.1.1 now references process specifications alongside procedures and work instructions, requiring these as separate documents. It also adds storage conditions to the items requiring documented control. A new requirement mandates reviewing these documents before making changes that affect food safety, legality or quality.
What is the new requirement in clause 6.1.7?
Clause 6.1.7 is a new requirement in BRCGS Issue 9. It states that products or materials outside the audit scope must be controlled to prevent safety, authenticity or legality risks.
What are the new labelling and pack control requirements in clause 6.2?
Clause 6.2.1 introduces label reconciliation, requiring processes to check label use against expected use and investigate inconsistencies. Clause 6.2.2 adds 'printed packaging and labels' terminology to product change procedures, and clause 6.2.3 clarifies that packing-run checks occur at predefined intervals and when printed packaging or labels arrive during production.
How can ASC Food Safety Consultants help with these BRCGS Issue 9 changes?
ASC Food Safety Consultants offers expert food safety support to help businesses prepare for the BRCGS Issue 9 changes. The article links to training courses, document toolkits and consultation booking. As a South Africa-based, SAATCA-accredited consultancy, ASC supports organisations in implementing the updated Process Control requirements.