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.

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