Last updated 7 October 2026
BRCGS Packaging Materials Issue 7 controls artwork in clause 5.2 and printing in clause 5.3. A converter needs an artwork procedure with a unique identifier for every version, customer approval that names that version, plates verified against it before mounting, superseded plates withdrawn the same day, a print risk assessment, and a recorded approval of every print run against the agreed standard.
A dairy customer adds an allergen advisory line to a shrink sleeve. New plates are made, and the old plates stay on the rack, unmarked. Three weeks later a repeat order runs from the old plates because both versions share a job number, and 40 000 sleeves leave without the advisory. That is the incident behind Kariega Flexibles’ story in ASC’s implementation course, a training scenario built from real audit patterns, and the customer found it at its own filling line.
Artwork and print control have no real equivalent in food manufacturing, and they are where converters get hurt. Implementation of BRCGS for Packaging Materials Issue 7 rebuilds them on Kariega’s press floor, alongside the other six sections, and you finish with a certificate of completion. About 18 hours, R5 380, no VAT added.
Why is artwork a product safety hazard for a packaging manufacturer?
Because printed packaging carries information the consumer relies on. A missing or wrong allergen statement, warning, declaration or date field can make the packed food unsafe or illegal, and the error usually starts at your artwork approval step.
That is why print error sits in the HARA under legality and labelling, and why artwork approval belongs on the flow diagram. South Africa’s labelling regulations put the allergen declaration duty on the food business, but your print decides whether the declaration reaches the shelf. The declarable allergens are listed in the eight allergens South African law makes you declare. When Kariega reconstructed the sleeve incident, six controls were missing, and any one would have stopped it:
- A job number specific to each artwork version.
- Unique identification on every plate.
- Plate identity verified against the approved artwork before mounting.
- A first-off check against the approved standard with a content checklist.
- Immediate physical withdrawal of superseded plates.
- A customer approval that named the version.
What must a BRCGS artwork management procedure cover?
Clause 5.2.1 asks for a procedure covering the artwork activities your site is responsible for. If the customer supplies print-ready files your responsibilities are narrower, but they never disappear.
A working procedure covers who collates the content and checks legal text against what source, version control with unique identifiers, proofing and independent checks, formal customer approval and who may accept it, release to origination and the press, change control and withdrawal of superseded versions, and storage of files and masters.
Then decide who owns it. At many converters approval sits with sales, which owns the customer and is under pressure to keep a launch moving. That pressure is what makes an unverified approval attractive. Kariega moved artwork approval from sales to the technical function in month 2, and that one change closed a Section 5 gap, a Section 1 responsibility gap and the root cause of the sleeve incident.
What counts as formal customer approval of artwork?
An approval you can tie to one identified version: a signed proof, a sign-off in an artwork system, or a written approval that names the version identifier. An email that says “looks good, go ahead” is not formal approval when two versions are in circulation, and the job should not run on it.
Under clause 5.2.2 the outcome must be documented. Every proof sent out carries its version identifier where nobody can miss it, and an approval that comes back without one is returned. Kariega now uses identifiers in the form JOBNUMBER-Vn on every file, proof, plate and job ticket. Give customer changes a single channel too. A tolerance change emailed to a sales rep and forwarded to production skips agreement, specification revision and HARA review in one step. If you print for export, read one artwork, several markets.
Learn Kariega’s artwork, first-off and line clearance rebuild lesson by lesson, then prove it in timed scenario checks, a case study and a practical stage on product and process control, all marked the moment you submit. Enrol in the BRCGS Packaging implementation course: R5 380, about 18 hours on any phone.
Not sure which course fits your job? WhatsApp ASC on +27 61 483 0381.
How do you stop the wrong plate reaching the press?
Identify every plate and cylinder with its artwork version, verify it against the job pack before mounting, link it to the approved origination, compare the first-off sample with the approved standard, and physically remove superseded plates the day they are replaced.
| Control | How it works | What it prevents |
|---|---|---|
| Unique identification (5.2.4) | Plate or cylinder etched or labelled with version and job reference | Mounting a superseded plate |
| Verification before mounting (5.2.4) | A named person checks identity against the job pack and signs | The right plate being assumed |
| Traceability to origination (5.2.4) | Records link each plate to the approved file | Not knowing which version printed |
| First-off comparison (5.3.3) | Printed sample compared with the approved standard before bulk running | A labelled plate that is damaged or wrongly made |
| Obsolete withdrawal (5.2.6) | Old plates destroyed, or quarantined in a marked, separate place, the same day | An old plate waiting beside the current one |
Obsolete artwork is the most dangerous item in a printing plant because it looks exactly like current artwork. Leave a superseded plate on the rack and it will eventually be mounted. Under 5.2.5, colour standards fade, so store them away from light, heat and solvent, date and replace them, control issue and return, and keep a master that never reaches the press floor. Under 5.2.7, electronic artwork needs controlled access, tested off-site backups and a change record. Your threat assessment under 4.4.1 should name artwork files as a target, and since P708 took effect on 10 August 2026 the people who do that assessment must be trained.
What must a first-off print approval record contain?
Clause 5.3.3 requires every print run, repeat jobs included, to be approved against the agreed standard and recorded. The record identifies the job, version and plate, the essential information checked against a list, the colour check, the signatures and a retained sample.
It rests on the print risk assessment under 5.3.1, which looks for loss of essential information, wrong versions, colour deviation where colour carries meaning, register defects that hide text, set-off and variant mixing. The course’s first-off record holds:
- Job and lot identification, date and time.
- The artwork version, checked against the approved standard and job pack.
- Plate or cylinder identity, verified.
- Essential information present and legible, checked against a defined list.
- Colour against the reference standard in the agreed viewing conditions.
- Signatures, two independent ones where it is a critical control measure.
- A retained first-off sample linked to the lot.
Kariega’s content checklist names the allergen line, declarations, date and lot fields, legal text and colour for that product. Checking against a list is far more reliable at 02:00 than checking that print “looks right”.
How should a converter handle print errors, composite print and leftover printed stock?
Detect errors during the run, mark them and record the metre position, remove them at slitting and verify the removal. Segregate composite print variants from the moment they are slit. Reconcile printed material against what was shipped, scrapped and kept.
Take register drift spotted 4 000 metres into a 12 000 metre run. Under 5.3.4, mark it and record the position, decide whether essential information is affected and what happens to material since the last good check, correct the press, then remove the affected material at slitting and verify it went. Recurring drift belongs in corrective action under 3.13.
Composite print under 5.3.5 puts look-alike variants side by side. Use a layout map, identify every daughter reel at slitting, stage and store variants apart, and quarantine any reel you cannot positively identify. Unused printed product under 5.3.6 must be accounted for, because missing branded print is a diversion risk. Line clearance under 5.4.9 fails on paperwork: an old job ticket, a reference sample beside the press, labels from the last run. Put documents and labels on the checklist as separate lines, with two signatures between different customers or variants. We show how these gaps become recalls in rework, packaging and line clearance.
Should artwork verification be a critical control measure?
It can be, and Kariega made it one. No later step would detect a wrong allergen declaration, the consequence for the consumer is severe, a clear pass or fail limit exists, and it can be monitored on every job at first-off. Managing artwork through validated prerequisite programmes is also defensible.
Kariega’s engineering manager argued that artwork was a quality control. The team kept it critical and recorded why in the HARA. The validation drew on the sleeve incident data and a trial of the two-person check against deliberately mismatched job packs. Many converters reasonably choose the other route, which then needs validation under clause 2.5.4. Neither route stands without the reasoning written down. The course’s calendar brings print and artwork control in around month 6, and the wider sequence is in the 12-month implementation plan.
Frequently asked questions
Which BRCGS Packaging Materials clauses cover artwork and print?
Clause 5.2 covers graphic design and artwork control, and clause 5.3 covers print control. Both sit in Section 5, product and process control.
Is an email approval of artwork acceptable under BRCGS?
Only if it names the unique version identifier of the artwork being approved. An email saying the proof looks good, without naming a version, is not a formal approval of an identified version.
What should happen to old printing plates when the artwork changes?
Remove them from the plate store on the same day and either destroy them or quarantine them in a clearly marked, separate location. Move the old file out of the live folder and withdraw old proofs from the press area.
Does every repeat print run need a first-off approval?
Yes. Clause 5.3.3 applies to each print run, so a job repeated every month is approved against the agreed standard and recorded every time.
Who should own artwork approval at a packaging converter?
The technical function, with a documented check of legal content and version identity before a plate is released to the press. Sales can keep the customer conversation.
Take control of artwork before the next version change
Implementation of BRCGS for Packaging Materials Issue 7 rebuilds artwork and print control the way a converter has to run them, inside a full implementation of all seven sections. Every activity is compulsory, timed and marked the moment you submit, with feedback naming the lesson to revisit. Nothing is uploaded and nothing waits for a trainer.
R5 380 for the full course. No VAT is charged, so the price shown is the price paid. Teams of five or more: contact ASC for a team rate.
- A full module on product and process control, from artwork to calibration and dispatch
- 9 modules and 84 lessons on one case study, Kariega Flexibles
- 17 scenario checks, 9 module case studies, 11 knowledge checks and 9 games, including “Stop the press”
- 4 practical stages done online, then a final assessment
- About 18 hours on a phone or laptop, and a certificate of completion
- Is it for me? Yes if you are a technical, QA or pre-press manager at a printing or converting site, a consultant, or an internal auditor.
- How long does it take? About 18 hours in short lessons. Artwork and print sit in Module 6.
- Will it work at my site? The controls apply to any site that prints packaging. Bring your own copy of the Standard.
New to the Standard? Start with Introduction to BRCGS for Packaging Materials Issue 7 (R1 195, about 13 hours), or get both courses in the BRCGS Packaging Materials bundle for R5 260. All options are on the ASC BRCGS training page.
The BRCGS Global Standard Packaging Materials Issue 7 is copyright and is not reproduced here. ASC is not affiliated with BRCGS.
Sources
- BRCGS Global Standard Packaging Materials Issue 7
- BRCGS Position Statement P708, Packaging Materials Issue 7
- Regulations Relating to the Labelling and Advertising of Foodstuffs (R146 of 2010), Foodstuffs, Cosmetics and Disinfectants Act 54 of 1972
- ASC course: Implementation of BRCGS for Packaging Materials Issue 7