BRCGS Packaging Materials Issue: 7 Key Requirements Packaging Manufacturers Must Control
BRCGS Packaging Materials Issue 7 has become an important benchmark for packaging manufacturers and converters that need to demonstrate control over product safety, quality, legality and authenticity.
Packaging is no longer viewed simply as a physical container around a product. For many applications, especially food and hygiene-sensitive products, packaging materials can directly influence product safety, consumer protection, regulatory compliance and brand reputation.
That is why an effective BRCGS system needs to go beyond documentation. It should demonstrate that risks are understood, processes are controlled, products are traceable and employees understand their responsibilities.
BRCGS describes Packaging Materials Issue 7 as a global industry benchmark for packaging excellence. The standard is applicable not only to food packaging producers but also to packaging manufacturers serving other applications across the supply chain.
In 2026, organisations also need to consider the latest official updates. BRCGS has issued P708 position statements for Issue 7, with the updated requirements effective for audits conducted from 10 August 2026.
What Is BRCGS Packaging Materials Issue 7?
BRCGS Packaging Materials Issue 7 is a global standard designed to help packaging operations demonstrate that their products are quality assured, legally compliant and authentic.
It applies to relevant operations involved in producing packaging materials for conversion or printing, supplying packaging materials from stock where further processing or repacking takes place, and manufacturing or supplying other unconverted or semi-converted packaging materials within the applicable scope.
The standard provides a structured framework covering product safety, quality, operational controls and risk management.
BRCGS guidance identifies Issue 7 as the current edition of the Packaging Materials standard.
Why BRCGS Packaging Certification Matters
Packaging manufacturers often operate within complex supply chains where their customers need confidence that packaging materials are consistently produced to defined requirements.
This becomes particularly important when packaging is used for food, beverages, pharmaceuticals, cosmetics, hygiene-sensitive products or other applications where packaging performance and safety can influence the final product.
BRCGS Packaging Materials certification can help organisations demonstrate a structured approach to:
- Product safety
- Product quality
- Legal compliance
- Product authenticity
- Risk management
- Traceability
- Operational control
- Continual improvement
BRCGS states that Packaging Materials certification is used globally and has become a benchmark for packaging excellence.
7 Key Requirements of BRCGS Packaging Materials Issue 7
1. Product Safety Culture
One of the important themes strengthened in Issue 7 is product safety culture.
A packaging safety system cannot depend entirely on procedures maintained by the quality department. People across the organisation need to understand how their decisions and behaviour can affect product safety and quality.
This means organisations should establish ways to develop, maintain and continually improve their product safety culture.
Communication, training, employee involvement and management commitment can all contribute to creating a stronger culture.
The objective is to make product safety part of everyday decision-making rather than something considered only before an audit.
2. Hazard Analysis and Risk Assessment
Packaging materials can present different types of risks depending on their intended use, raw materials, manufacturing processes and customer requirements.
BRCGS Packaging Materials Issue 7 updated requirements for hazard analysis and risk assessment systems, including alignment with relevant Codex Alimentarius principles.
Organisations should understand the hazards associated with their materials and processes and establish appropriate controls.
Risk assessment should reflect actual operations rather than being treated as a generic document.
3. Product Safety and Quality Controls
A BRCGS system needs to demonstrate consistent control over the characteristics of packaging materials that matter to customers and their intended use.
This can involve specifications, raw-material controls, process parameters, testing, inspection, product release and management of nonconforming products.
The exact controls will depend on the type of packaging being produced and its intended application.
The key principle is simple: the organisation should be able to demonstrate that its processes consistently produce packaging that meets defined requirements.
4. Traceability
Traceability is a critical element of an effective packaging management system.
An organisation should be able to establish the relationship between relevant incoming materials, production activities and finished products.
Effective traceability can become particularly important when an issue is identified and the organisation needs to determine which materials, production batches or customers may be affected.
BRCGS has also published guidance addressing traceability across its standards, highlighting the importance of establishing traceability through relevant stages of manufacture, processing and distribution.
For packaging manufacturers, traceability should therefore be tested rather than assumed.
5. Control of Outsourced Processes
Packaging operations may rely on external organisations for certain processes, services, testing or other activities.
Issue 7 provides greater clarity around outsourced activities, making it important for organisations to understand which activities are performed externally and how associated risks are controlled.
Outsourcing a process does not automatically remove the manufacturer’s responsibility for ensuring that the relevant requirements are met.
Organisations should therefore establish appropriate controls, specifications, supplier expectations and verification activities for applicable outsourced processes.
6. Allergen Risk Assessment Where Applicable
Allergen-related risks are particularly relevant when packaging materials may come into contact with food products or when manufacturing environments involve materials that could create contamination concerns.
Issue 7 includes requirements relating to allergen risk assessment and appropriate controls where allergens are identified as a relevant risk.
The controls should be based on the organisation’s actual processes and risk assessment rather than applied mechanically to every packaging operation.
7. Continual Improvement and Audit Readiness
BRCGS certification should not be treated as a one-time project.
Issue 7 places emphasis on continual improvement and effective implementation of management systems.
Internal audits, corrective actions, trend analysis, management review and performance evaluation can help organisations identify weaknesses and improve their systems.
A mature organisation should be able to demonstrate that findings lead to meaningful corrective action rather than simply closing observations on paper.
What Changed With BRCGS Packaging Materials Issue ?
BRCGS published Issue 7 in October 2024 after a revision process intended to clarify and strengthen requirements and address common nonconformities associated with the previous edition.
BRCGS identified several key themes during the development of Issue 7, including:
- Evolution of product safety culture
- Updated hazard analysis and risk assessment requirements
- Continual improvement
- Global applicability
- Alignment with GFSI benchmarking requirements
- Clarification of outsourced activities
- Traceability requirements
- Allergen risk assessment where applicable
- Additional audit options
The standard also expanded its scope to address certain products at the boundary between packaging and consumer products, including some single-use disposable products.
BRCGS explains that these changes were intended to reflect current industry practices, emerging risks and changing expectations across the packaging sector.
Important 2026 Update: P708 Position Statement
Packaging manufacturers should not rely only on the original Issue 7 document when preparing for an audit.
In 2026, BRCGS issued P708, the position statement for Packaging Materials Issue 7. The updated position statement became effective for audits conducted from 10 August 2026.
BRCGS has stated that these updates were part of its alignment with the GFSI Benchmarking Requirements 2024.
Therefore, organisations preparing for a current BRCGS Packaging Materials audit should make sure they are working with the latest applicable position statement as well as the current edition of the standard.
BRCGS position statements should be checked for the latest official updates.
Common BRCGS Packaging Certification Mistakes
Treating Certification as Documentation Only
A large collection of procedures does not automatically demonstrate an effective packaging safety and quality system.
Auditors need to see evidence that processes are actually implemented.
Ignoring Product Safety Culture
A policy alone is not enough. Organisations should be able to demonstrate how product safety culture is communicated, implemented and improved.
Using Generic Risk Assessments
Risk assessments should reflect the organisation’s actual raw materials, processes, products and intended applications.
Weak Traceability Testing
Having a traceability procedure is different from proving that the system works when tested.
Failing to Control Outsourced Activities
External processing or services can introduce additional risks if responsibilities and verification controls are unclear.
Preparing Only Immediately Before the Audit
Last-minute preparation often identifies symptoms rather than underlying system weaknesses.
A stronger approach is to maintain continuous internal verification and improvement throughout the certification cycle.
How to Prepare for a BRCGS Packaging Materials Audit
Organisations preparing for certification or recertification can use a structured approach.
- Define the certification scope and confirm that the organisation’s activities fall within the applicable BRCGS Packaging Materials scope.
- Conduct a gap assessment against the current Issue 7 requirements and applicable position statements.
- Review hazard analysis and risk assessment against actual materials, processes and intended uses.
- Evaluate product safety culture through communication, training, awareness and employee involvement.
- Review traceability and perform practical traceability tests.
- Evaluate outsourced activities and confirm that relevant external processes are adequately controlled.
- Review product specifications and testing to ensure requirements are defined and consistently verified.
- Conduct internal audits across relevant functions and operational areas.
- Analyse corrective actions and verify that identified problems have been effectively addressed.
- Check current BRCGS updates before the certification audit, including applicable position statements.
BRCGS itself provides a self-assessment tool to help sites measure their operation against the requirements before a certification audit.
Why BRCGS Packaging Materials Is Valuable for International Suppliers
For packaging manufacturers supplying international customers, demonstrating product safety and quality can become an important part of commercial credibility.
BRCGS states that its Packaging Materials standard is used globally and is often preferred by brands, retailers and specifiers.
Certification can therefore support organisations seeking to strengthen customer confidence and demonstrate that their packaging processes operate against a recognised benchmark.
It can also provide a structured framework for improving operational controls, traceability and risk management.
How Shark Certification Can Support BRCGS Packaging Requirements
Shark Certification currently lists BRCGS Food & Packaging among its specialised consultancy offerings.
Shark states that its support includes areas such as risk management, traceability, food safety culture, gap analysis, implementation, internal audits and preparation for certification.
For a packaging organisation, the practical objective should be to build a system that works consistently across production, quality, procurement, testing, documentation and management rather than preparing only for an external audit.
Explore BRCGS Food & Packaging or contact Shark Certification to discuss your requirements.
Frequently Asked Questions About BRCGS Packaging Materials
What is BRCGS Packaging Materials?
BRCGS Packaging Materials is a global standard designed to help packaging operations demonstrate that their products are quality assured, legally compliant and authentic, with controls addressing product safety and operational requirements.
What is the current BRCGS Packaging Materials issue?
The current edition is BRCGS Packaging Materials Issue 7.
When was BRCGS Packaging Materials Issue 7 published?
BRCGS published Issue 7 in October 2024.
What are the main BRCGS Packaging Materials Issue 7 requirements?
Important areas include product safety culture, hazard analysis and risk assessment, product quality, traceability, outsourced activities, applicable allergen controls, continual improvement and effective operational controls.
What is P708 in BRCGS Packaging Materials?
P708 is the BRCGS position statement for Packaging Materials Issue 7. The current updated position statement became effective for audits conducted from 10 August 2026.
Is BRCGS Packaging Materials recognised internationally?
Yes. BRCGS states that Packaging Materials is used globally and has become an industry benchmark for packaging excellence.
Who needs BRCGS Packaging Materials certification?
It can be relevant to packaging manufacturers, converters and other packaging operations within the scope of the standard, particularly where customers, brands, retailers or markets require recognised packaging safety and quality assurance.
Does BRCGS Packaging Materials apply only to food packaging?
No. BRCGS states that the standard is used not only by food packaging producers but also by producers of packaging for other applications across the supply chain.
Can Shark Certification help with BRCGS Packaging certification?
Yes. Shark Certification lists BRCGS Food & Packaging among its specialised consultancy services and provides support around gap analysis, implementation, risk management, traceability, internal audits and certification preparation.
Conclusion: Packaging Quality Starts Before the Product Reaches the Customer
BRCGS Packaging Materials Issue 7 provides a structured framework for organisations that need to demonstrate control over packaging safety, quality, legality and authenticity.
The strongest implementation goes beyond documentation. It connects risk assessment, product safety culture, traceability, process control, supplier management, testing, internal auditing and continual improvement.
For organisations preparing for certification in 2026, staying current is equally important. The latest P708 position statement demonstrates why packaging manufacturers should regularly monitor official BRCGS updates rather than relying solely on the original Issue 7 publication.
Ultimately, BRCGS certification should not be viewed simply as a certificate for the wall.
It should demonstrate that the packaging leaving your operation is consistently controlled, traceable, compliant and fit for its intended purpose.
