BRCGS Packaging Materials Issue 7: A Practical Guide for Manufacturers

What is the BRCGS Packaging Materials standard?

BRCGS Packaging Materials is the BRCGS standard for the safety, quality and legality of packaging. Brands and retailers use it to approve packaging suppliers through a single third-party audit, carried out by a BRCGS-approved certification body.

In its Guide to Certification, BRCGS says the standard suits manufacturers of packaging and packaging materials for food and non-food applications. It also covers companies that produce materials for conversion or printing, companies that supply packaging, and companies that manufacture or supply raw materials used in packaging.

Across Morocco and the wider African packaging industry, that means:

• extruders and printers of flexible packaging (films, pouches, lidding);
• corrugated and folding carton makers;
• metal can and end manufacturers supplying fish, fruit and vegetable canneries;
• glass container and closure makers;
• plastic bottle and preform producers;
• traders who resell packaging without manufacturing it.

Certificated sites appear in the BRCGS Directory, which buyers use to check suppliers. On the GFSI side, the page of recognised programmes still lists Packaging Materials Issue 6, and Issue 7 is among the programmes undergoing benchmarking against version 2024 (GFSI pages checked on 5 November 2026): check this status before relying on GFSI recognition of Issue 7 with a buyer.

What changed with Issue 7?

Issue 7 replaced Issue 6 for every audit from 28 April 2025. BRCGS published it on 28 October 2024, together with its Interpretation Guideline, giving sites and auditors six months to prepare.

For a site certified under Issue 6, this is more than a renumbering exercise. The logic of the standard is the same — management commitment, hazard control, quality system, site, process, people — but several expectations have been clarified. BRCGS details these changes in its guide to key changes; here we stick to the new features published on its official page.

Several points can be checked on the official standard page:

Our advice: do not start from your old Issue 6 manual. Redo the gap analysis requirement by requirement with the BRCGS self-assessment checklist, then rewrite only what needs rewriting.

How is the standard structured, and what are fundamental requirements?

The standard is organised in sections that follow the life of the system, from senior management commitment to personnel. Some clauses are fundamental requirements: they cover systems considered essential, and a serious failure against one of them puts certification at risk.

The table below follows the seven sections of Issue 7, as presented in the official BRCGS self-assessment checklist (P701); use the last column as a reading grid, not as a quotation of the standard.

The official self-assessment checklist marks eight of them: senior management commitment and continual improvement, hazard analysis and risk assessment (HARA), specifications, internal audits, traceability, housekeeping and cleaning, manufacturing process control, and training and competence of personnel. The grades and the consequence of a major non-conformity against one of them are set by the Issue 7 audit protocol, which the certification body applies.

The BRCGS Guide to Certification highlights one point worth remembering: understand "the objectives of fundamental clauses and statements of intent". Each fundamental requirement opens with a statement of intent. That is what the auditor keeps in mind when judging whether your practice meets the objective, even if your procedure is worded differently.

How do you run a hazard analysis and risk assessment (HARA) for packaging?

A HARA starts with one question: what will the packaging be used for, and what will it touch? It follows the logic of the Codex Alimentarius HACCP principles, applied to a product that is not a food but can contaminate one.

A tray for raw meat, a film for cheese, a can for sardines in oil and a corrugated shipping case do not carry the same hazards. The most common weakness we find in African packaging plants is a generic HARA, copied from a template, that does not describe the products actually made or the customers' end use.

Our method has eight steps:

1. Build the team: quality, production, maintenance and someone who knows the customers and the end use.
2. Describe the product: materials, inks, varnishes, adhesives, layers, direct or indirect food contact, type of food (fatty, acidic, moist, dry), conditions of use (retort, microwave, freezing).
3. Draw the process flow, from goods-in to dispatch, including rework and in-house regrind, and verify it on the floor.
4. Identify hazards at each step: physical (glass splinters, metal particles, blade fragments), chemical (migration, ink set-off, solvent residues, lubricants), microbiological where the end use requires it, and contamination from pests or people.
5. Assess the risk of each hazard by likelihood and severity, with a written, consistent method.
6. Define control measures: prerequisite programmes for low risks, specific monitored controls for significant ones.
7. Set monitoring, limits and corrective actions for the control points you retain.
8. Verify and review the analysis for every new product, material, machine, complaint or incident, and at least once a year.

This is the checklist we use to review a HARA before the audit:

• The analysis covers every product family in the certification scope.
  
• End use and the type of food in contact are described for each family.
  
• The process flow has been verified on the floor and dated.
  
• Chemical hazards from inks, varnishes, adhesives and solvents are identified.
  
• Suppliers' declarations of compliance for food contact materials are current.
  
• The risk scoring method is written and applied consistently.
  
• Each control point has monitoring, a limit, an owner and a corrective action.
  
• The last review is less than a year old and reflects recent changes.
  

How does BRCGS Packaging relate to the PPWR, applicable since 12 August 2026?

The two files overlap but do not replace each other. BRCGS Packaging shows a customer that you control the safety and quality of your packaging; Regulation (EU) 2025/40, known as the PPWR, sets legal obligations for packaging placed on the EU market.

The PPWR has applied since 12 August 2026. Its obligations are staggered: there is no single date for everything. Harmonised labelling, for instance, will apply at the earliest from 12 August 2028, and recyclability requirements come later: under Article 6, design for recycling applies from 1 January 2030, or 24 months after the delegated acts setting the criteria enter into force if that is later; recycling at scale from 2035; and from 2038 only recyclability grades A or B remain allowed. For food contact packaging, Article 5 has prohibited since 12 August 2026 placing on the market packaging above PFAS limit values: 25 ppb for any targeted PFAS, 250 ppb for the sum of targeted PFAS, 50 ppm for all PFAS.

For a packaging maker in Morocco, Egypt or Kenya, the link runs through the European customer. The importer or brand placing packaging on the EU market has to demonstrate compliance and will ask its supplier for the data. Before placing packaging on the market, the manufacturer as defined in the Regulation carries out the conformity assessment, draws up the technical documentation set out in Annex VII and an EU declaration of conformity (Articles 15, 38 and 39); the importer checks that these documents exist (Article 18). These obligations have applied since 12 August 2026, and the documents must be kept for 5 years for single-use packaging and 10 years for reusable packaging.

A BRCGS-certified site already has most of the foundations: current specifications, material traceability, document control and change management. Our article on the PPWR for non-EU exporters and packaging makers covers the obligations and an action plan, and our PPWR and packaging page describes our regulatory support.

What are the steps and timelines of an Issue 7 certification?

BRCGS describes eight steps, from reading the standard to issuing the certificate. The only timelines BRCGS sets apply after the audit: 28 days to close non-conformities and 42 calendar days from the first audit day to issue the certificate.

How long preparation takes (steps 1 to 5) depends on where you start. A site already certified to ISO 9001, with solid traceability, is not in the same position as a workshop that has never run a quality system. In the projects we support, the observed duration ranges from 3 to 12 months depending on the starting point: maturity of the system, condition of the buildings, existing hazard analysis basis and availability of the team. This is an observed range, not a guarantee.

The most cost-effective last step is a mock audit a few weeks before the real one. It exposes the gaps the team no longer sees, especially in the HARA, declarations of compliance and foreign body control.

Should you aim for BRCGS Packaging or another standard?

For a manufacturer of packaging used in the food industry, BRCGS Packaging Materials is the reference standard in the BRCGS family. The choice belongs to your customers: ask them in writing which certificate they accept before you start the project.

If your customer is itself certified to BRCGS Food Safety, it has to control its food contact packaging suppliers; our guide to BRCGS Food Safety Issue 9 certification explains what it will expect from you. To compare GFSI standards by export market, read our BRCGS vs IFS vs FSSC 22000 comparison.