What is the starting point of this case study?
A packaging manufacturer certified to ISO 9001 for several years, whose system works but is ageing. The case is composite: it brings together situations we often see in packaging and printing plants in Morocco, without describing a real company. The profile and timeline are illustrative.
The company prints and converts folding cartons and flexible packaging in the Casablanca region. It runs two shifts. Its customers are Moroccan food manufacturers, several of which export, and one European brand owner. It is certified to the 2015 edition of ISO 9001; its recertification falls in the first half of 2028. A food customer is also asking it for BRCGS Packaging Materials Issue 7 certification, a project under way.
The quality manager combines quality, hygiene and part of safety. The management review takes place every year, but mostly repeats the previous minutes. The context analysis dates from the last overhaul of the system.
When should the transition audit be scheduled?
At the 2028 recertification, after checking that the certification body will be ready. That is the choice we would recommend in this situation, for three reasons drawn from the Global ACI transition document, the mandatory reference for accredited certification bodies.
Option | Advantage | Limit in this case |
|---|---|---|
2027 surveillance audit | Early transition | The certification body must have completed its own transition, by 30 September 2027 at the latest; very short preparation |
Recertification in the first half of 2028 | Full system audit; additional time may not be needed; more than a year of margin before 30 September 2029 | None, if the gap analysis starts early |
Special audit in 2029 | Flexible date | One more audit in the cycle, and less margin to close a major nonconformity |
Management asks the certification body to confirm in writing the transition of its accreditation, the format of the audit and the planned duration. The backward schedule starts from that date: gap analysis, updates, training, evidence period, internal audit, management review. The detailed deadlines are in our article on the ISO 9001:2026 transition deadline.
Which gaps does the gap analysis reveal?
Few documentary gaps, many gaps in practice. The gap analysis follows the three topics the transition audit reviews at a minimum: changed requirements, changes in context, other changes needed.
Clause | Finding (case study) | Action decided | Evidence expected at audit |
|---|---|---|---|
4.1 and 4.2 Context | Analysis never reread; climate change never examined, although the 2024 amendment requires it; the European brand owner asks about recyclability and carbon footprint | New context analysis, climate change judged relevant for customer expectations and heat-sensitive stock | Dated, reasoned analysis approved by management |
5.1.1 and 7.3 Quality culture and ethics | On the night shift, out-of-tolerance print runs are sometimes released to make the truck’s departure time; press operators hesitate to stop the machine | A “stop and report” rule backed by management, awareness sessions in Arabic and French, reports thanked in team meetings | Attendance sheets, operator interviews, share of defects detected internally |
5.2.1 Policy | Policy signed years ago, with no link to the export strategy | Policy rewritten from the context analysis and management’s direction | Dated policy, communicated and understood by supervisors |
6.1.1 to 6.1.3 Risks and opportunities | Single register; opportunities copied as the mirror image of risks | Register split; two opportunities treated in their own right: a new customer segment, a digital printing line | Actions, owners, deadlines, follow-up |
6.3 Changes | A folder-gluer installed with no success criterion and no review | Change sheet with an effectiveness criterion (waste, complaints), a communication plan and a review of results | Completed sheet and dated review of results |
9.3.2 Management review | No heading on changes in the expectations of customers and other interested parties | New agenda covering every input | Complete minutes, with decisions |
The most sensitive finding is the night shift’s. It is not a missing procedure: the release procedure exists. It is quality culture in the sense of the new Note 2 to clause 5.1.1, quoted by Global ACI: shared values, attitudes, established practices. The answer comes from management and supervisors, not from a document revision. Climate change, for its part, is not new in 2026: the joint IAF–ISO communiqué introduced it in 2024. This site simply had ground to make up.
How does the PPWR come into the transition?
Through customer expectations, not through the standard. Regulation (EU) 2025/40 on packaging and packaging waste, known as the PPWR, has applied since 12 August 2026, with staggered obligations and harmonised labelling from 12 August 2028 at the earliest. ISO 9001 does not impose it. But when the European brand owner passes on its new requirements, such as a declaration of conformity or recyclability, these are requirements of a relevant interested party.
In the case study, they come in at three points: the analysis of context and interested parties (4.1 and 4.2), the review of requirements for products, and the management review, which must now include changes in the needs and expectations of interested parties (9.3.2 c). The detail of the obligations is covered on our PPWR and packaging page. To place these requirements: the Regulation defines the “manufacturer” as whoever manufactures the packaging or, where the packaging is designed or manufactured under its name or trademark, that brand owner (Article 3). Before placing packaging on the market, the manufacturer draws up the technical documentation and the EU declaration of conformity with the requirements of Articles 5 to 12, recyclability included (Articles 6 and 15). When the packaging bears the European customer’s brand, these obligations are the customer’s, and they reach the case-study company as customer requirements.
For a European buyer, the point is practical: a supplier whose management review tracks your new requirements is more likely to meet them on time.
The BRCGS Packaging Materials Issue 7 project follows its own logic, that of packaging product safety. The two projects nonetheless share document control, internal audit, corrective action and management review: building a single system avoids paying for the transition twice. See our page on the packaging and printing sector.
How does the plan run up to the audit?
In five phases, following the backward schedule, with a sufficient evidence period before the audit.
- Gap analysis and framing. Gap report, written confirmation from the certification body, a project team bringing together the quality manager, the shift team leaders and the sales manager.
- Updates. Context analysis, policy, register of risks and opportunities, change sheet, management review agenda. Nothing else is rewritten.
- Training. Management and supervisors on quality culture and ethics, process owners on clauses 6.1 and 6.3, internal auditors on all the changed clauses, delivered in-house.
- Evidence period. Awareness sessions on both shifts, one real change managed from start to finish, opportunities followed up, reports recorded.
- Internal audit and management review. Internal audit against the 2026 edition, then a complete management review, a few weeks before the recertification audit.
The order of steps and the full checklist are in our 8-step ISO 9001:2026 transition plan; the time budget is discussed in our article on the ISO 9001:2026 transition audit cost. What changes in the standard, clause by clause, is explained in our guide to the ISO 9001:2026 transition.
What a packaging site can take from this case study: