What does Issue 7 change for a packaging manufacturer?
Issue 7 is the only version packaging sites have been audited against since April 2025. BRCGS published it in October 2024; the official English self-assessment checklist (P701A), released with the Standard, is dated 28 October 2024.
For a managing director or a quality manager, the change comes down to three points, as BRCGS itself presents them in its October 2026 review:
- the fundamental requirements were strengthened: there are eight, including the HARA (section 2);
- clauses were introduced or enhanced on allergens and on single-use disposable products used in food service;
- the revision was led by a technical working group of 35 experts from around the world: manufacturers, regulators, technical experts, certification and accreditation bodies, and trade organisations.
The Standard kept moving after publication. Position statement P708, published on 12 May 2026 and effective from 10 August 2026, amends two clauses following the assessment of Issue 7 against the 2024 GFSI benchmarking requirements. Product defence (4.4.1) now requires the people who carry out the threat assessment to be trained. Cleaning (4.8.2) now covers disinfection where appropriate, with validation and verification based on the product’s intended use. The common protocols BRCGS079 (unannounced audits) and BRCGS080 (blended audits), which apply to Packaging Materials Issue 7, were updated on 6 October 2026.
BRCGS details the changes from Issue 6 to Issue 7 in its guide to key changes. The method does not depend on it: a site still documented against Issue 6 redoes its gap analysis on the Issue 7 self-assessment checklist, then builds in P708.
On recognition, the GFSI page of recognised programmes, consulted on 5 November 2026, still lists Packaging Materials Issue 6, recognised against version 2020 of the GFSI requirements; the GFSI page of programmes undergoing benchmarking against version 2024 lists Packaging Materials Issue 7. No benchmarking decision had been published at that date. The full timeline, and what to watch in 2027, are covered in our article on the Issue 7 timeline and GFSI status.
Is your site in scope, and how do you draw the boundary?
Yes, if you produce packaging materials for conversion or printing, supply packaging materials, or make or supply raw materials used in packaging, for food or non-food use: that is the audience BRCGS gives the Standard in its Guide to Certification. The certificate, however, covers only what you declare. The HARA must include every product and manufacturing operation within the intended scope of certification (clause 2.3.1).
These are the scope decisions we meet most often in Morocco and West Africa.
Situation | What Issue 7 says | What you need to decide |
|---|---|---|
You resell packaging bought in, without converting it | Section 7: HARA for traded products (at least receipt, storage and dispatch), approval of the last manufacturer, specifications, legality, traceability | Include these products in scope, or exclude them and tell the customer |
A step is carried out by a third party (printing, laminating, cutting) | Clause 3.8: step declared to the customer, its risks built into the HARA, written specification that includes traceability, final release by your site | A written list of outsourced steps and their controls |
The site also handles products outside the scope | Clause 5.4.10: those products and areas must create no risk for certified products | What is in scope and what is out, line by line |
A customer requires an additional module | Modules 10 and 11 are voluntary, assessed as pass or fail, outside the grade | Add the module and notify the certification body before the audit |
You make single-use disposables for food service | BRCGS reports introduced or enhanced clauses on these products | Confirm the scope in writing with the certification body |
Write the scope during the gap analysis and confirm it with the certification body before the quote: it sets the audit duration, and therefore the budget (see our article on BRCGS Packaging certification cost and timeline). A site that also processes food may need two standards: see our BRCGS certification hub and our guide to BRCGS Food Safety Issue 9.
What do the eight fundamental requirements demand?
Each fundamental requirement opens with a statement of intent, which the auditor assesses on top of the detailed clauses. The official P701 self-assessment checklist flags eight of them in Issue 7. The consequence of a non-conformity raised against the statement of intent of a fundamental requirement is set by the Issue 7 audit protocol, which the certification body applies.
Clause | Fundamental requirement | What the site must be able to show |
|---|---|---|
1.1 | Senior management commitment and continual improvement | A policy signed by the person with overall responsibility for the site; a product safety and quality culture plan with defined activities (communication, training, staff feedback, behaviours, performance measurement); a confidential reporting system; monitored objectives |
2 | Hazard analysis and risk assessment (HARA) | A multidisciplinary team with a competent leader; microbiological, physical and chemical hazards; migration, recycled materials, foreseeable unintended use, malicious intervention, fraud, allergens; validated critical control measures and limits; review at least once a year |
3.4 | Specifications | Specifications for raw materials, work in progress and finished products; a statement of compliance for each product made for contact with food, beverages or hygiene-sensitive products, compiled by a competent person and reviewed |
3.5 | Internal audits | A programme spread over the year, every activity audited at least once a year, auditors independent of the activity, a separate programme of building and equipment inspections |
3.10 | Traceability | Links from raw materials to the customer and back, outsourced steps included; tested at least once a year, achievable within 4 hours; maintained through rework and recycling |
4.8 | Housekeeping and cleaning | Cleaning schedules stating responsibility, area, frequency, method, materials and verification; risk-based frequencies; since P708, disinfection where appropriate and cleaning that is validated and verified; microbiological environmental monitoring where the risk justifies it |
5.4 | Manufacturing process control | Potential defects listed step by step, process control points with documented settings, checks at start-up, after adjustments and during production, signed line clearance at every start-up and changeover |
6.1 | Training and competence | Staff trained before they start work, temporary staff and contractors included; specific training for control points and critical control measures; records; training delivered in the trainees’ language |
Two rows of this table cause the most failures. According to BRCGS, the second year of Issue 7 audits brought critical non-conformities linked to HARA implementation and to the use and effectiveness of internal audits. On the shop floor, that looks like a HARA written when the system was set up and never revisited after a change of ink, film or machine, or internal audits that check binders without ever going into production.
Clause 6.1.2 deserves particular attention in Morocco: training must be delivered in the appropriate language of the trainees. For a team of operators, that often means Arabic or Darija, the Moroccan Arabic dialect, with materials to match. The same applies to any site whose operators do not work in the language of its quality system.
Which evidence will the auditor look for in your trade?
The requirements are the same for everyone, but the hotspots change from one trade to another. These are the ones we prepare first on the sites we support.
Printers (flexo, gravure, offset, labels). Clause 5.2 calls for an artwork management procedure, documented formal approval by the customer, checks that plates, cylinders, anilox rollers and blankets match the approved version before use, and protection of electronic files against loss or malicious intervention. Clause 5.3 requires an assessment of the risks of losing essential information and of mixing printed product, approval of each print run against the agreed standard, a system that detects print errors during the run and, for composite print, segregation of print variants. Unless otherwise agreed with the customer, substandard trademarked materials are rendered unusable or handed to a specialist contractor that provides records of destruction (clause 4.10.5).
Plastics converters (films, preforms, trays). Clause 4.10.2 requires process waste (pellets, flake, powder, dust and offcuts) to be managed so that as little as possible reaches the environment. A pellet spillage is one of the incidents the incident management procedure must cover (clause 3.14.2). Recycled materials belong in the product description (2.3.2) and in the critical-use parameters agreed with the customer, migration testing included (5.1.1). Module 10, on plastic pellet loss prevention, is audited on site only.
Paper and board. Storage off the floor and away from walls (5.8.1), pest management across the whole site, seasonal variation included (4.11.1), and pallet checks before use (5.9.3) are the classic issues. BRCGS lists PFAS and mineral oils among the sector’s emerging concerns: your paper, coating and ink suppliers must be able to document what they deliver.
Metal packaging. Sharp implements and metal are controlled through an issue and replacement procedure, and snap-off blade knives are banned (4.9.2). Internal lacquers and coatings belong in the HARA, as chemical hazards and for migration.
Glass. The glass and brittle materials register in clause 4.9.1 covers glass other than the product: windows, lighting, instruments. Breakage of the product itself is handled in the HARA and by in-line inspection equipment, whose effectiveness is verified at the start and end of runs (5.6.4).
Hygiene and foreign-body controls by material family are covered in detail in our how-to on packaging hygiene and contamination control.
How does the audit work: announced, blended or unannounced?
A site’s first audit is announced and fully on site. The programme then changes under two BRCGS protocols that apply to Packaging Materials: BRCGS079 for unannounced audits and BRCGS080 for blended audits. A site may also choose a fully unannounced programme.
Programme | When | Rules to know |
|---|---|---|
Announced, on site | First audit, then according to the cycle | Date agreed with the certification body; the most senior manufacturing or operations manager attends the opening and closing meetings, and a member of senior management discusses the culture plan (clause 1.1.9) |
Blended announced | Recertification only, never an initial audit | Remote part for requirements coded blue (records, systems, documents); on-site part for requirements coded orange (facilities, HARA, good practice, traceability test) within 28 days of the remote part; Module 10 on site only |
Mandatory unannounced | At least one audit every three years; the first in one of the two years after the initial audit | Year notified by the certification body within three months of the previous audit, never the date; four-month window before the audit due date; contract signed before the window opens; no more than 10 non-audit days, justified and notified at least four weeks in advance |
On the day of an unannounced audit, the auditor holds a short opening meeting and starts the production inspection within 30 minutes of arriving. The quality manager’s absence is no reason to postpone: a deputy must be named. Refusing access leads to suspension of the certificate and a major non-conformity.
After the audit, the rules are the same for every programme: 28 days to submit corrections, root cause analysis and the preventive action plan; the certificate is issued no later than 42 calendar days after the first audit day if certification is granted. If the number or level of non-conformities prevents certification, a new full announced audit takes place no earlier than 28 days later, with the same certification body unless BRCGS grants a derogation. A site cannot change certification body in the four months before its re-audit due date without BRCGS’s written agreement.
The grade follows the audit. The common protocols refer to grades from AA to D, a “+” after an unannounced audit (AA+ or A+, for example) and a next audit at 12 or 6 months depending on the grade. The detailed scale, which links the number and level of non-conformities to each grade, is set in the Issue 7 audit protocol.
Which route should you follow, from gap analysis to certificate?
The official BRCGS route has eight steps, from reading the Standard to the certificate. It sets no minimum period before the audit, but the audit assesses real practice: the system must already be running in production.
Step | What you do | Official BRCGS tool | Trap to avoid |
|---|---|---|---|
Read | Standard and Interpretation Guideline, which BRCGS recommends using together | Standard free of charge from the BRCGS Store; Interpretation Guideline | Working from a copy that is not genuine or is out of date (clause 1.1.7) |
Learn | Project lead and HARA team trained on the requirements | Two-day BRCGS course for sites | Training a single person who then leaves |
Self-assess | Gap analysis, requirement by requirement | P701 checklist, in English (P701A) or French (P701E) | Presenting it as an internal audit: BRCGS states that it is not one |
Prepare | Action plan, HARA, prerequisite programmes, specifications, statements of compliance, procedures | — | Writing without checking on the lines |
Run | Records, traceability test, recall test at least once a year (3.14.5), internal audits | — | Creating every record in the month before the audit |
Mock audit | Full audit under real audit conditions | — | A lenient mock audit |
Certification audit | Audit by a BRCGS-approved certification body | Certification body search on brcgs.com | A date set before the HARA is solid |
Certificate and maintenance | Close-out of non-conformities, listing in the BRCGS Directory, monitoring of position statements | Directory, position statements | Missing P708 or a new version of a protocol |
Before you ask a certification body for a quote, check that these ten pieces of evidence exist and are dated:
How do Issue 7, ISO 9001:2026 and the PPWR fit together?
By building a single system, because your customers ask questions that mix all three. ISO 9001:2026 provides the foundation: document control, internal audits, management review. It asks for no HARA, no food-contact statement of compliance and no hygiene programme: that is what Issue 7 adds.
Regulation (EU) 2025/40, the Packaging and Packaging Waste Regulation (PPWR), has applied since 12 August 2026 to packaging placed on the EU market. It is not the same thing as BRCGS, which remains a private, voluntary certification. But three Issue 7 requirements produce evidence your European customer will ask for under the PPWR: the statement of compliance (3.4.3), the HARA that addresses migration and recycled materials (2.5.1), and clause 5.6.6, which requires any test critical to safety or legality to be performed by a laboratory that is accredited or operates to the requirements and principles of ISO/IEC 17025. That covers a PFAS analysis sent to an outside laboratory.
PPWR obligations and roles are covered in detail in our PPWR guide for non-EU exporters and on our PPWR for packaging page. Our case study of a flexible packaging printer shows how one evidence file serves both the BRCGS audit and a European brand’s PPWR questionnaire.