The release of BRCGS Packaging Materials marks a significant evolution in packaging standards, reflecting the growing importance of sustainability, food safety, and operational excellence.
This guide provides a detailed comparison of the changes introduced in Issue 7, ensuring businesses can seamlessly transition and meet the updated requirements.
Our ASC Food Safety Consultants team is here to guide you through these changes, ensuring your business not only achieves compliance but thrives in this new era of packaging standards that includes the latest requirements to align with the already published BRCGS standards.
We have highlighted the key updates introduced in BRCGS Issue 7 and how they differ from Issue 6.
Need help with BRCGS Issue 7? We are here to help! GET IN TOUCH
What’s New in BRCGS Packaging Materials?
Issue 7 ensures global applicability and relevance by aligning with updated international standards such as BRCGS Food Safety and FSSC 22000 Packaging, which ensures alignment with the latest GFSI requirements.
The updates introduced in BRCGS Packaging Materials emphasise:
- Fostering a safety culture by encouraging leadership and employee involvement to uphold stringent safety standards.
- This version also prioritises enhanced traceability processes, minimising risks more effectively.
- Additionally, it advances operational excellence through stricter requirements for site standards, product defence, and process controls.
- Due to the dynamic nature of the packaging industry, Issue 7 expands its scope to accommodate modern production techniques, innovative materials, and sustainability goals.
- The certification now includes disposable items like paper cups and napkins, provided they follow the same manufacturing processes as traditional packaging materials.
- It also addresses risks associated with sustainable and recycled materials, requiring companies to verify their safety and suitability for intended use.
Additional changes include:
Emerging Packaging Technologies – Expanded Scope
What’s new? Issue 7 now covers digitally printed packaging, biodegradable materials, and compostable packaging.
Why it matters: Businesses using innovative materials like plant-based plastics or sustainable composites can now certify under BRCGS, ensuring compliance with updated safety and hygiene standards.
Stronger Risk-based Thinking
What’s new? Risk assessments must now include environmental factors, supply chain vulnerabilities, and hygiene practices.
Why it matters: This shift ensures a proactive, dynamic approach to identifying and managing risks, rather than reacting to issues after they arise.
Enhanced Hygiene and Environmental Monitoring
What’s new? Structured microbiological testing, air quality monitoring, and hygiene zoning are now mandatory.
Why it matters: These measures protect public health by reducing contamination risks during packaging production.
Product Safety and Quality Culture
What’s new? Organisations must demonstrate a strong safety culture through leadership, employee engagement, and continuous training.
Why it matters: Embedding safety values into daily operations ensures consistent compliance and long-term success.
Tighter Supplier Approval and Monitoring
What’s new? Businesses must implement ongoing supplier evaluations, focusing on material safety, ethical sourcing, and regulatory compliance.
Why it matters: Strengthened supplier controls reduce the risk of non-compliant materials entering your production process.
Alignment with ESG Principles
What’s new? Issue 7 integrates Environmental, Social, and Governance (ESG) considerations.
Why it matters: Demonstrating sustainable practices enhances your brand’s reputation and meets growing consumer and regulatory demands.
Key Differences Between Issue 6 and Issue 7
Senior Management Commitment
Issue 6 emphasised a general commitment to product safety and quality, but Issue 7 raises the bar by requiring organisations to demonstrate continuous improvement in safety culture. New clauses have been added to introduce features such as confidential reporting systems, clear guidelines for unannounced audits, and mandatory senior management presence during certification reviews. Personnel are now expected to actively report risks and signs of unsafe conditions, making safety a shared responsibility.
Hazard Analysis and Risk Assessment (HARA/HACCP)
The hazard analysis in Issue 6 was broad, but Issue 7 introduces clearly defined subclauses aligned with updated CODEX Alimentarius principles. Even terminology has been refined, “Critical Control Points” are now called “Critical Control Measures” to reduce ambiguity and drive more consistent implementation across the industry.
Outsourced Processes and Traceability
Where Issue 6 offered basic supplier approvals, Issue 7 includes outsourced service providers in the documentation process. Traceability is also sharpened, businesses now need to demonstrate the ability to conduct product group traceability tests within four hours, unless otherwise dictated by law.
Issue 6 provided general guidance for allergen control, but Issue 7 requires a formal allergen management plan. This plan must include legal labelling requirements tailored to the country of sale, bringing a new layer of precision to consumer safety.
Allergen Management
Issue 6 provided general guidance for allergen control, but Issue 7 requires a formal allergen management plan. This plan must include legal labelling requirements tailored to the country of sale, bringing a new layer of precision to consumer safety.
Incident Management and Response
Several upgrades stand out here. Issue 7 includes guidance on identifying what qualifies as an “accident” and mandates prompt notification to certification bodies within three working days of significant incidents, none of which were specified in Issue 6.
Site Standards: Buildings and Utilities
The requirements for site infrastructure have become more detailed. Issue 7 breaks down structural expectations for elements like walls, ceilings, and doors, and includes a new focus on how utilities impact product integrity. These additions support better sanitation and maintenance oversight.
Product Defence and Equipment Management
Issue 7 provides deeper guidance around product defence strategies to protect against intentional harm. When it comes to equipment, specifications must be established before sourcing, with commissioning driven by risk-based assessments.
Environmental Monitoring
In Issue 7, annual reviews of environmental monitoring are now required unless site conditions change, providing more consistent oversight of hygiene and contamination risks.
Product and Process Control
Perhaps the most expansive shift: Issue 7 introduces six new clauses that clarify managing equipment failures, retaining identifiable product samples, and ensuring conformity to legal or customer specifications. Procedures for out-of-scope products/materials and validation of inspection protocols are also now required.
Audit Protocol
Audit protocol now provides 3 options:
- Announced Audits, Full announced audits are conducted on-site, with one audit in the 3-year cycle being unannounced.
- Blended Audits – Only available for sites with certification, the 3-year cycle consists of a remote audit of the documentation followed by an in-person site audit, with one unannounced visit.
- Unannounced Audits, This is voluntary, with one compulsory unannounced audit in a 3-year cycle. There has also been a change to Lapsed Certificates.
Conclusion
The transition to BRCGS Packaging Materials represents a significant step forward in packaging standards, driven by an increased focus on sustainability, enhanced food safety, and operational excellence. This updated issue expands its scope to include modern production techniques and materials, integrating environmental, social, and governance (ESG) principles, and reinforcing a proactive, risk-based approach to safety and quality.
Navigating these changes, from stricter requirements for senior management commitment and comprehensive risk assessments to mandatory hygiene zoning and tighter supplier controls, is crucial for businesses aiming to maintain compliance and thrive in the evolving packaging industry. The updated audit protocols also offer more flexibility while emphasising unannounced audits within the certification cycle.
How can we Help?
If you’re ready to align your systems with the latest standards, now’s the perfect time to take action, and if you need support along the way, expert guidance is just a click away. CONTACT US HERE
At ASC Food Safety Consultants, we specialise in helping businesses navigate complex transitions like this. Our services include:
- Gap Analysis: Identify areas where your current systems fall short of Issue 7 requirements.
- Training Programmes: Equip your team with the knowledge and skills to implement new standards.
- Supplier Evaluations: Strengthen your supply chain with robust approval and monitoring systems.
- Hygiene and Environmental Controls: Design and implement effective hygiene zoning and monitoring protocols.
- Internal Audits: Prepare for certification with comprehensive internal audits aligned with Issue 7.
Our BRCGS Issue 7 Training Options
Comments
Key facts
- BRCGS Packaging Materials Issue 7 aligns with updated international standards such as BRCGS Issue 9 and FSSC 22000 Packaging, and now covers disposable items like paper cups and napkins that follow the same manufacturing processes.
- Issue 7 renames "Critical Control Points" to "Critical Control Measures" and aligns hazard analysis subclauses with updated CODEX Alimentarius principles.
- Traceability tests for product groups must now be demonstrated within four hours unless the law dictates otherwise, and outsourced service providers are included in the documentation process.
- Issue 7 requires a formal allergen management plan with legal labelling requirements tailored to the country of sale, and mandates notifying certification bodies within three working days of significant incidents.
- It emphasises safety culture through leadership and employee engagement, adds risk-based thinking with environmental and supply-chain factors, and integrates Environmental, Social and Governance (ESG) considerations.
- Issue 7 offers three audit protocols: announced audits, blended audits (certified sites only), and voluntary unannounced audits, each involving an unannounced element within the three-year cycle.
Frequently asked questions
What is new in BRCGS Packaging Materials Issue 7?
Issue 7 aligns with updated international standards such as BRCGS Issue 9 and FSSC 22000 Packaging to ensure global applicability. It emphasises safety culture, enhanced traceability, stricter site standards, product defence and process controls, and expands scope to modern production techniques and sustainability goals. It also now includes disposable items like paper cups and napkins that follow the same manufacturing processes as traditional packaging.
What are the key differences between BRCGS Issue 6 and Issue 7?
Issue 7 raises the bar on senior management commitment by requiring demonstrated continuous improvement in safety culture, including confidential reporting systems and mandatory senior management presence during certification reviews. It renames "Critical Control Points" to "Critical Control Measures," includes outsourced service providers in documentation, and requires a formal allergen management plan. It also adds more detailed site infrastructure requirements and six new product and process control clauses.
What are the traceability requirements under BRCGS Issue 7?
Under Issue 7, businesses must demonstrate the ability to conduct product group traceability tests within four hours, unless otherwise dictated by law. Issue 7 also includes outsourced service providers in the documentation process, extending traceability expectations beyond in-house operations.
What audit options are available under BRCGS Issue 7?
Issue 7 provides three audit protocols. Announced audits are full on-site audits with one unannounced audit in the three-year cycle. Blended audits, available only for certified sites, combine a remote documentation review with an in-person site audit plus one unannounced visit. Unannounced audits are voluntary, with one compulsory unannounced audit in the three-year cycle.
How does BRCGS Issue 7 handle allergen management and incident reporting?
Issue 7 requires a formal allergen management plan, which must include legal labelling requirements tailored to the country of sale. For incident management, it provides guidance on identifying what qualifies as an "accident" and mandates prompt notification to certification bodies within three working days of significant incidents.
How can ASC Food Safety Consultants help with BRCGS Issue 7?
ASC Food Safety Consultants offers gap analysis, training programmes, supplier evaluations, hygiene and environmental controls, and internal audits to support Issue 7 compliance. They also provide two training courses: Introduction to BRCGS for Packaging Materials Issue 7 (FS17) and Implementation of BRCGS for Packaging Materials Issue 7 (FS18).
Thank you for sharing this clear and practical summary of the changes in BRCGS Issue 7. The detailed breakdown of how risk-based thinking, allergen management, traceability and infrastructural requirements have been strengthened gives great insight. At dishajute.com we’re committed to aligning our packaging practices with the highest standards of quality and sustainability, so we found your post especially timely. Looking forward to applying some of these learnings in our own supplier audits and quality system updates!
Thanks so much for the kind words! We’re really glad to hear the article was helpful. We offer a range of services to support clients who are BRCGS Issue 7 certified.
If you’re looking to save time compiling documents from scratch, feel free to explore our
BRCGS Issue 7 Document Templates Toolkit.
And if you’d like a deeper understanding of the requirements, we recommend our
Introduction to BRCGS Issue 7 Online Self-paced Course.
Let us know if you have any questions — we’re here to help!