BRCGS Packaging and PPWR Case Study: A Flexible Packaging Printer

What was the printer’s starting point?

A site well run in the ISO 9001 sense, but one that had never been audited on the safety of its packaging. This is a composite case: it brings together situations our teams meet at Moroccan packaging manufacturers, without describing any client.

The company is based in an industrial zone south of Casablanca, Morocco’s main industrial city. It prints plastic films by flexography, laminates them with adhesives, slits them into reels and makes pouches. It runs two shifts. Its customers are Moroccan biscuit and confectionery makers, several of which export, and, more recently, two European food brands that buy printed reels for their own packing lines.

Both brands set the same listing condition: a BRCGS Packaging Materials Issue 7 certificate. A few weeks later, their purchasing teams sent a PPWR questionnaire covering PFAS, recycled content, recyclability of the laminates and information for the EU declaration of conformity.

Which scope and role decisions came first?

Two decisions, made in writing before any documentation work: what the certificate covers, and who is who under the PPWR.

For the scope, management chose printing, laminating, slitting and pouch making, at a single address. The plates, made off site, are treated as printing equipment: each plate is checked against the approved version before use and remains traceable to the file the customer approved (5.2.4). The plate supplier is approved and monitored as a service provider (3.9). A small activity reselling plain films was excluded from the scope, and the exclusion was put in writing for customers.

For the PPWR, the question was simple to ask and slow to document. According to the European Commission, each packaging item has only one manufacturer; for sales packaging, it is normally the filler, often also the brand owner. The two European brands fill the pouches under their own names: they are the manufacturers, and the printer is their supplier. It must pass them the information and documentation they need for their EU declaration of conformity (Article 16). Each brand confirmed this split in writing.

What gaps did the gap analysis reveal?

The gap analysis, run on the official Issue 7 self-assessment checklist in French, the language of the site’s managers, showed that the decisive gaps were on the lines.

• HARA: there was no hazard analysis. Built with a team drawn from quality, production, pre-press and maintenance, it brought out three major hazards: ink set-off from the printed side to the food-contact side on the reel, migration of ink and adhesive constituents, and mixed print between two variants for the same customer. The adhesive curing time before reels are released, set with the adhesive supplier, became a control point.
• Artwork and printing: old file versions were still accessible on the shop floor. A procedure for artwork changes and removal of obsolete versions (5.2.6), recorded approval of each print run against the agreed standard (5.3.3) and segregation of variants in composite print (5.3.5) were put in place.
• Foreign bodies: the snap-off blade knives at slitting were replaced, blades are now issued and counted, the tubes in the colour-viewing booths were protected (4.2.6), and a glass and brittle materials register was created (4.9.1).
• Cleaning: schedules existed but had never been validated. Since position statement P708, effective from 10 August 2026, cleaning standards must be validated and verified against the product’s intended use; surface swabs were organised on the pouch-making machine, the one closest to the food-contact side.
• Traceability: the link between reel, ink batch, adhesive batch and film batch had never been tested. The first test revealed adhesive batches not recorded when drums were changed; once corrected, the test is now run on every product group, within the 4-hour target (3.10.4).
• Internal audits: they checked documents. The programme was spread over the year, extended to the HARA and the prerequisite programmes, and given to auditors who do not audit their own work (3.5).

How did one evidence file serve both BRCGS and the PPWR?

By making the Issue 7 statement of compliance the core of a sheet per reference. Clause 3.4.3 already requires, for every food-contact product, a statement compiled by a competent person that 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 material. All that remained was to attach the data the brands asked for under the PPWR.

On PFAS, the printer first asked its ink, varnish, adhesive and film suppliers to confirm, with evidence, that no PFAS were intentionally added. It then had the most exposed references analysed, with the brands’ agreement. In the absence of a harmonised method, the Commission’s guidance document recommends a stepwise approach to enforcement that starts with total fluorine: a sample below 50 mg/kg could be considered compliant. The Article 5 limits are 25 ppb for any PFAS measured by targeted analysis, 250 ppb for the sum of PFAS measured by targeted analysis and 50 ppm for PFAS including polymeric PFAS.

On recyclability, the printer documented the exact composition of each laminate without making commitments on its customer’s behalf: the design-for-recycling criteria will apply no earlier than 1 January 2030, and the brand, as manufacturer, decides on the design. PPWR obligations and timelines are detailed in our PPWR guide for non-EU exporters and in our PPWR and PFAS checklist.

How was the audit prepared?

By building up on real production, then a mock audit with no complacency. The project lead and the HARA team were trained on the Issue 7 requirements, and the operators on hygiene and process control, in Arabic, the language of the teams, as clause 6.1.2 requires.

The system then ran over several production cycles: line clearance records at every changeover (5.4.9), traceability test, recall test with timings of key activities (3.14.5), internal audits. Management formalised its product safety and quality culture plan, and the production director prepared to present it during the audit (1.1.9).

The mock audit found two weaknesses: a line clearance not signed on the pouch machine during a format change, and a shared pre-press folder that still held an old artwork. Both were corrected before the certification audit was booked.

The first audit is announced and fully on site: blended audits are for recertification only. The contract with the certification body already provides for the unannounced audit, which will take place in one of the two years after the initial audit: justified non-audit days, maintenance shutdowns notified, deputies named for the quality manager and the production director.

What lessons apply to other printers and converters?

Four lessons apply beyond this site:

1. Decide the scope and the PPWR role in writing, before the first document.
2. A printer’s HARA turns on migration and mixed print, not on a generic list of hazards.
3. The statement of compliance per reference is the key document, for the audit and for the brand.
4. Ink, adhesive and film suppliers are on the critical path: involve them from the first month.

Before you start a similar project, check these points:

• Each customer has stated in writing the standard, issue, modules and deadline expected.
  
• The PPWR role for each reference is confirmed in writing with the brand.
  
• The HARA covers ink set-off, migration and mixed print.
  
• Each food-contact reference has its statement of compliance, reviewed at every change.
  
• Suppliers have sent their declarations and PFAS information.
  
• Plates are checked and traced, and obsolete versions removed.
  
• Cleaning of the areas closest to the food-contact side is validated and verified.
  
• The traceability test links the reel shipped to the ink, adhesive and film batches.
  

To go further: our guide to BRCGS Packaging Materials Issue 7, the packaging hygiene and contamination control checklist and the cost and timeline factors of a project.