What is BRCGS Packaging Materials Issue 7?
BRCGS Packaging Materials is the BRCGS certification standard for manufacturers of packaging and packaging materials, for food and non-food applications. After an independent audit, it shows that the packaging you deliver is safe, legal and of controlled quality. Issue 7 is the current version: BRCGS published it in October 2024 and audits have been carried out against it since April 2025.
Three facts for a managing director or a buyer:
- the certificate is issued by a BRCGS-approved certification body, never by a consultant;
- the Standard can be accessed free of charge via the BRCGS Store, according to the BRCGS Guide to Certification;
- in October 2026, BRCGS reported that more than 7,100 manufacturing sites in 94 countries were certified to the Standard.
BRCGS describes Packaging Materials as the first packaging standard recognised by GFSI. As of 5 November 2026, however, the GFSI list of recognised programmes still shows Issue 6, recognised against version 2020 of the GFSI requirements, and Issue 7 appears on the page of programmes undergoing benchmarking against version 2024: no decision had been published at that date. A buyer who requires a “GFSI-recognised” certificate should therefore confirm in writing that it accepts Issue 7, the only version now audited.
Issue 7 does not stand alone. BRCGS publishes position statements that become mandatory from their effective date. For Issue 7, document P708 amended two clauses from 10 August 2026 to align the Standard with the 2024 GFSI benchmarking requirements: product defence (clause 4.4.1) and cleaning (clause 4.8.2).
Which companies need it?
Any company that manufactures or supplies packaging and packaging materials, or makes raw materials used in packaging. That is how BRCGS defines the audience in its Guide to Certification. The Standard also covers traded products: a site that resells packaging it does not make handles them in a dedicated section.
Across Morocco, West Africa and the Middle East, the request nearly always comes from an exporting food customer or an international brand. The table shows the profiles we meet most often; the points of attention refer to Issue 7 requirements.
Profile | Example (anonymised) | What the auditor will look at |
|---|---|---|
Flexible packaging printer | A film printer in Casablanca supplying biscuit and dairy plants | Artwork and pre-press, print tooling, mixed print runs, inks, statement of compliance |
Plastics converter (films, preforms, trays) | An extruder in Kenitra supplying berry packers | Foreign bodies, recycled materials, migration, process waste and pellets |
Paper and board | A carton maker in the Souss supplying citrus packhouses | Storage, pest control, inks, reel and batch traceability |
Metal packaging | A can and end maker supplying fish canneries on the Atlantic coast | Internal lacquers and coatings, metal contamination, critical dimensions agreed with the customer |
Glass | A bottle and jar plant supplying olive oil and preserves | Glass breakage, in-line inspection, areas with exposed contact surfaces |
Labels and sleeves | A self-adhesive label printer in Rabat or Abidjan | Accuracy of printed information, version control, destruction of obsolete labels |
Packaging trader | A distributor importing trays and reselling them unchanged | HARA for traded products, supplier approval, specifications, legality, traceability |
To choose between the five BRCGS standards, or for a site that needs both Food Safety and Packaging Materials, see our BRCGS certification hub.
How is Issue 7 structured?
Issue 7 has seven sections of requirements plus an audit protocol. The official P701 self-assessment checklist, released by BRCGS together with the Standard, flags eight requirements as "fundamental". Each opens with a statement of intent, which the auditor assesses in addition to the detailed clauses; the consequence of a non-conformity raised against that statement is set by the Issue 7 audit protocol, which the certification body applies.
Section | What it covers | Fundamental requirements |
|---|---|---|
1. Senior management commitment | Commitment and continual improvement, product safety and quality culture plan, management review, organisation and responsibilities | 1.1 Senior management commitment |
2. Hazard and risk management | HARA team, prerequisite programmes, product description, flow diagrams, hazard analysis, critical control measures, limits, monitoring, corrective action, validation and verification | 2 Hazard analysis and risk assessment |
3. Product safety and quality management | Documents and records, specifications, internal audits, suppliers, product vulnerability and claims, outsourcing, traceability, non-conforming materials, complaints, corrective action, incidents | 3.4 Specifications; 3.5 Internal audits; 3.10 Traceability |
4. Site standards | External standards, buildings, utilities, security and product defence, layout and flow, equipment, maintenance, cleaning, contamination control, waste, pest management | 4.8 Housekeeping and cleaning |
5. Product and process control | Development, artwork and pre-press, print control, process control, calibration, inspection and testing, incoming goods, storage, dispatch | 5.4 Manufacturing process control |
6. Personnel | Training and competence, personal hygiene, staff facilities, medical screening, protective clothing | 6.1 Training and competence |
7. Traded products | HARA, approval and monitoring, specifications, testing, legality and traceability of traded products | None |
- Printers and label makers: clauses 5.2 (artwork and pre-press) and 5.3 (print control) require an artwork procedure, formal customer approval, verification of plates, cylinders and anilox rollers before use, protection of electronic files, and a risk assessment for loss of information and mixed print.
- Plastics converters: clause 4.10 requires process waste (pellets, flake, powder, dust, offcuts) to be managed to minimise release to the environment, and the HARA must address recycled materials.
- All food-contact sites: clause 3.4 requires a statement of compliance for every product made for direct contact with food, beverages or hygiene-sensitive applications.
That statement is compiled and signed off by a competent person. As a minimum it describes the materials used, confirms compliance with legal requirements in the country of manufacture and, where known, the country of use, and declares any post-consumer recycled content. It carries an issue date, any limitations of use and, where relevant, the usable life, and it is reviewed at a set frequency or whenever something relevant changes.
How does Issue 7 handle packaging hygiene?
Through risk and the intended use of the finished product. As set out in the official self-assessment checklist, Issue 7 does not place sites in a fixed hygiene category: it asks them to scale their controls to what the packaging will become, especially when it will be in direct contact with food or other hygiene-sensitive products. The audit scope covers the products and operations the site declares: the hazard and risk analysis must include all of them, and the scope is confirmed in writing with the certification body before the quote.
In practice this means:
- Areas: areas where exposed food or hygiene-sensitive contact surfaces are present must be defined, identified, monitored and controlled.
- Cleaning: frequency and methods based on risk. Since 10 August 2026, position statement P708 adds disinfection where appropriate and requires cleaning to be validated and verified against the risk of the product’s intended use. The glossary now defines disinfection.
- Environmental monitoring: where justified by risk, considering the survival of micro-organisms on materials and the product’s intended use, a microbiological programme checks that cleaning works. It is reviewed at least once a year and whenever the process, flow or equipment changes.
- Utilities: the quality of steam, ice, air and compressed gases in direct contact with the product is specified or monitored, based on risk assessment.
- People: hygiene rules, protective clothing and exclusion criteria based on risk and on the intended use of the finished product.
Take a tray maker supplying berry packers for European supermarkets. The right question is not "are we high hygiene?" but "what happens to the fruit if our tray is contaminated, and how do we prove our controls every day?". The answer drives clothing rules, line cleaning, protection of stock and sampling frequency.
What do the HARA and product safety culture require?
The HARA (hazard analysis and risk assessment) is the core of Issue 7 and a fundamental requirement. It is the packaging equivalent of a food plant’s HACCP plan: it identifies every hazard to product safety and legality and sets the controls.
What the auditor expects:
- a multidisciplinary team (quality, technical, operations and, where relevant, engineering and product development) with up-to-date expertise;
- documented prerequisite programmes built into the HARA;
- a description of each product, including its intended use and restrictions on use, such as direct food contact;
- flow diagrams verified on site at least once a year and whenever they change;
- a hazard analysis at each step that considers, among other things, migration of substances and recycled materials;
- critical control measures, validated limits, monitoring and defined corrective actions;
- validation before any change, regular verification and at least an annual review, including new legislation.
Where the HARA identifies a potential for allergen contamination, the site must run an allergen management plan that meets labelling law in the country of sale. BRCGS notes that Issue 7 introduced new or enhanced clauses in this area.
Product safety culture is the other pillar. Senior management defines a plan to develop the site’s product safety and quality culture, with measurable activities. During the audit, a member of the senior team must be available to discuss its implementation, and the most senior operations manager attends the opening and closing meetings.
BRCGS itself gives the warning sign: in the second year of Issue 7 audits, it reports critical non-conformities linked to HARA implementation and to the effectiveness of internal audits. A HARA written by an outsider and never reviewed will not hold.
How does certification work?
Certification follows the official route in the BRCGS Guide to Certification. The ACG method shown on this page follows the same logic.
BRCGS step | What happens | Who acts |
|---|---|---|
Getting started | Read the Standard and Interpretation Guideline, contact a BRCGS-approved certification body | The site |
Learn | Practical training on Issue 7 requirements | The site, with a trainer |
Review | Self-assessment gap analysis, team set-up and training, consultancy if needed | The site, with a consultant |
Prepare | Action plan, risk assessments, control points, procedures, internal audits | The site, with a consultant |
Plan audit | Date agreed with the certification body, staff availability | Site and certification body |
On-site audit | Observation of practices, document review, staff interviews | The certification body |
Non-conformities | Corrective action, root cause analysis, preventive action, close-out within 28 days | The site |
Certification | Report review; certificate issued within 42 calendar days of the first audit day | The certification body |
The Standard is graded. Additional modules are assessed as pass or fail and their non-conformities do not affect the grade. Grades run from AA to D, with a “+” after an unannounced audit (AA+ or A+, for example), and the next audit falls 12 or 6 months later depending on the grade; the scale linking the number and level of non-conformities to each grade is in the Issue 7 audit protocol.
Three audit programmes exist:
Programme | When | Rule to know |
|---|---|---|
Announced, fully on site | First audit, unless the site itself requests an unannounced audit; then according to the cycle | Date agreed with the certification body |
Blended announced (BRCGS080) | Recertification only, never an initial audit | A remote part (documents, records), then an on-site part |
Unannounced (BRCGS079) | At least one audit every three years in an announced programme, the first within either of the two years after the initial audit; or a fully unannounced programme, at the site’s choice | The certification body states whether the next audit is announced or not; up to 10 non-available days can be nominated |
Where an unannounced audit applies, the site must make sure it can take place: contract agreed with the certification body before the four-month window opens, and the body kept informed of production shutdowns.
Which additional modules are available?
BRCGS offers two voluntary modules for Issue 7, both published on 10 March 2025.
Module | Purpose | For whom |
|---|---|---|
Module 10: Plastic Pellet Loss Prevention | Containment of mainly pre-production plastic waste that could reach the environment | Plastics converters, film and preform makers; also usable with the Consumer Products standard |
Module 11: Meeting tms Global Quality Standard requirements | Helps the suppliers concerned meet those requirements during the Issue 7 audit | Sites that make or supply packaging for tms / HAVI |
To add a module, the site notifies its certification body before the next audit. A module usually extends the audit, and it is assessed separately as pass or fail. For a plastics converter in Tangier supplying European groups, Module 10 builds on an obligation it already has: clause 4.10 requires it to control process waste, pellets included.
How does BRCGS Packaging Issue 7 relate to the PPWR?
Closely, but they are not equivalent. BRCGS is a private, voluntary certification; Regulation (EU) 2025/40 (PPWR) is EU law that has applied since 12 August 2026, with staggered obligations. The BRCGS page for the Standard does not mention the PPWR, and a certificate is not a regulatory declaration of conformity.
What Issue 7 does is require much of the evidence your EU customers will ask for under the PPWR. Here is our reading of where they meet.
PPWR obligation | Date | What Issue 7 already requires | What remains to be done |
|---|---|---|---|
PFAS limits for food-contact packaging (Article 5) | 12 August 2026 | Statement of compliance (3.4), chemical hazards and migration in the HARA (2), acceptance criteria for incoming materials (5.7) | PFAS test evidence, with your ink, varnish and paper suppliers |
EU declaration of conformity drawn up by the manufacturer, based on supplier information (Articles 16 and 39) | Depends on the requirement | Specifications and statements of compliance kept up to date (3.4) | Information sheets in the format your customer needs |
Design for recycling (Article 6) | 1 January 2030 at the earliest | Critical-use parameters, recycled materials and migration at development stage (5.1) | Assessment against the future delegated acts |
Harmonised labelling (Article 12) | 12 August 2028 at the earliest | Artwork and print control (5.2 and 5.3) | Plan the artwork changes for your customers |
Recycled-content claims (Article 12, voluntary label) | 12 August 2028 at the earliest | Claims and chain of custody (3.7), traceability of recycled materials (3.10) | Batch-level evidence of recycled content |
Weight and volume minimisation (Article 10) | 1 January 2030 | Specifications (3.4) and product development (5.1) | Technical documentation requested by the manufacturer |
Obligations, dates and roles (manufacturer, supplier, importer) are covered in detail on our PPWR for packaging page. For the wider ESG picture, see our ESG and CSR hub.
Moving from Issue 6 to Issue 7
A site certified to Issue 6 is now audited against Issue 7. BRCGS says Issue 7 strengthened the fundamental requirements and introduced new or enhanced clauses, including on allergens, and that the revision aimed to help sites identify hazards, run risk assessments, set critical limits and strengthen product safety culture. In its October 2026 review, BRCGS also mentions new or enhanced clauses on single-use disposable products for foodservice, and a revision led by a working group of 35 experts: manufacturers, regulators, certification and accreditation bodies. Since then, position statement P708 has added its two changes, on product defence and cleaning. BRCGS also publishes a guide to the key changes, to be read with the self-assessment checklist.
The safest method does not depend on that detail: redo the gap analysis requirement by requirement on the Issue 7 checklist, build in position statement P708, then test the system with a mock audit.
Is your site ready for an Issue 7 audit?
Check these points with your management team before booking an audit.
If more than three boxes are empty, start with a gap analysis rather than an audit date.
Why use a consultant, and which one?
BRCGS’s own certification route mentions obtaining consultancy during the self-assessment stage. The choice is yours, and so is the risk. Choose on verifiable evidence:
- listing in the official BRCGS consultant directory for Packaging Materials;
- real experience of your material family: paper and board, plastics, metal, glass or printing;
- precise deliverables, including the HARA and statements of compliance, not just a number of days;
- a commitment never to act as your site’s certification auditor.
ACG supports packaging manufacturers towards BRCGS Packaging Materials in Morocco and across Africa and the Middle East. The firm reports 502 projects, 32 consultants and experts and a 100% success rate on the certifications it has supported. Missions combine on-site visits at key stages with remote follow-up, so a plant in Côte d’Ivoire, Senegal or Egypt keeps the same pace as one in Casablanca.
Next steps:
- our food safety training, including BRCGS Packaging and HARA, within the training catalogue; for Moroccan companies, funding may fall under OFPPT special training contracts: see CSF / OFPPT funding, with a simulation and no promised amount;
- and, for a first conversation, describe your project.