A packaging converter is given fourteen months by a customer to achieve BRCGS certification. The technical manager writes procedures for eleven of them, books the audit, and fails on internal audits, management review and corrective action. Not because the system was wrong, but because it had been running for three weeks. Implementing BRCGS Packaging Materials Issue 7 is a timing problem before it is a documentation problem, and the nine fundamental requirements are where the timing bites.
In short
- BRCGS Packaging Materials Issue 7 has seven sections and 269 sub-clauses. Nine sub-sections are designated fundamental, and a lack of focus on any of them may result in certification not being granted.
- The fundamentals are 1.1, 2.0, 3.4, 3.5, 3.10, 3.13, 4.8, 5.4 and 6.1. They were chosen precisely because they cannot be implemented quickly before an audit.
- A realistic first certification project is 12 to 14 months. What sets the earliest audit date is not how fast you write procedures, but how long your slowest fundamental needs to produce a history of records.
- Issue 7 was published on 28 October 2024 and became effective for audits from 28 April 2025. Position statement P708 then amends two clauses for audits from 10 August 2026.
- Start internal audits, training, management review and corrective action in month 1. Everything else can be caught up. These cannot.
What the Standard actually asks of you
Strip away the 269 sub-clauses and almost every requirement in Issue 7 resolves into the same four questions. Once you can see the pattern, the Standard stops being 269 separate problems and becomes one problem repeated.
| What an auditor wants | What that means in practice | Where sites lose marks |
|---|---|---|
| A decision made on the basis of risk | Someone competent looked at your products and processes and decided what control is needed. | The decision was never written down, so it looks like an accident rather than a judgement. |
| A documented procedure | The decision is captured as an instruction someone else can follow. | The procedure describes an ideal factory, not this one. |
| Evidence it happened | Records, signed and dated, going back far enough to show a pattern. | Records exist for the last three weeks because the audit was announced. |
| Evidence it works | Verification, review, internal audit, trending, corrective action when it did not work. | Nobody ever checks that the procedure is still followed or still makes sense. |
The nine fundamental requirements, and why they set your audit date
The Standard designates certain requirements as fundamental because they relate to systems crucial to establishing and operating an effective safety and quality operation. Look at the list and the logic is obvious: these are the controls that cannot be implemented quickly before an audit, and whose output can actually be assessed.
| Fundamental | Minimum evidence history to aim for | Start it in month |
|---|---|---|
| 1.1 Senior management commitment and continual improvement | Policy signed and communicated, objectives set and reviewed at least once, culture plan with activities and a measure that has moved | 1 |
| 6.1 Training and competence | Needs identified, delivery recorded, competence assessed, refresher schedule running, agency staff and contractors inducted | 1 |
| 3.5 Internal audits | A programme spread across the year covering the whole Standard, with a meaningful portion complete and findings closed | 1 to 2 |
| 3.13 Corrective and preventive action | Real non-conformities raised, root cause investigated, actions verified effective months later | 2 |
| 4.8 Housekeeping and cleaning | Schedules with a defined standard, validated methods, verification records across months | 2 |
| 2.0 Hazard analysis and risk assessment | Complete HARA, flow diagrams verified on the floor, validation, verification, one full review | 2 to 3 |
| 3.4 Specifications | Raw material and finished product specifications agreed and in date, statements of compliance authorised by a competent person | 3 |
| 3.10 Traceability | Full forward and backward trace tested against a target time, with quantity reconciliation | 4 |
| 5.4 Manufacturing process control | Control points defined with limits, checks at start-up and after adjustment, line clearance records | 4 |
The single most common planning error
Sites plan as though every gap takes the same time to close, then discover four weeks out that the requirements carrying the most weight needed a running start. You cannot produce six months of internal audit records in a week. You cannot retrofit training records. You cannot demonstrate that corrective action works without corrective actions that were raised, investigated and closed over time.
Step 1: scope and audit option, before you build anything
Two decisions come first, because both change what you build. The scope is the description that appears on your certificate and that your customers will read; it must cover the processes and products that actually happen on site, and any exclusion must be justified rather than declared. The audit option determines your calendar.
| Audit option | How it works | What it demands of your system |
|---|---|---|
| Announced | You agree a date with the certification body. Announced audits may be taken in the 28 calendar days up to and including the audit due date. One audit in every three-year cycle must still be unannounced. | The most forgiving route, but the mandatory unannounced audit means you cannot build a system that only works when a date is known. |
| Blended announced | A split audit, part remote and part on site. Available only within the announced programme. | Rewards good electronic records and punishes paper archives, because part of the review happens remotely. |
| Unannounced | Every certification and recertification audit is unannounced, occurring at any point in the last four months of the audit cycle. | No preparation window at all. A strong signal to customers, and unforgiving of any system that relies on a tidy-up week. |
For a first certification, the announced route is usually the right commercial choice. Plan as though it were unannounced anyway: a system that only performs when a date is known guarantees a problem at the mandatory unannounced audit inside the first cycle.
Step 2: the gap analysis that becomes your project plan
This is the most valuable week of the project, and most sites waste it by producing a list of things they do not have. A gap analysis is a plan, sorted by how long each gap takes to close and how much certification risk it carries. Score every sub-clause on a scale rather than yes or no.
| Score | Meaning | What it implies |
|---|---|---|
| 0 Absent | No decision, no document, no record. | Full build. If it is a fundamental, this is your critical path. |
| 1 Informal | It happens but is undocumented and depends on individuals. | Document what already works, then add records. Usually fast. |
| 2 Documented, not implemented | A procedure exists; the floor does not follow it. | Decide which is right, fix that one, then build evidence. |
| 3 Implemented, not verified | It happens and is recorded, but nobody checks it works. | Add verification, review and trending. Where most ISO 9001 sites sit. |
| 4 Compliant | Decision, procedure, records and verification all present. | Sample it to confirm, then leave it alone. |
Then sort on two axes, not one. Effort is the axis everyone uses and the less important of the two. A fundamental requirement with a long lead time and a score of 0 or 1 is your critical path, whatever the effort involved. Do the analysis in pairs, one technical and one operational, and walk the floor for every requirement coded as good manufacturing practice. A gap analysis done entirely at a desk will be wrong in exactly the places that cost you on the day.
The number that sets your audit date
Not the total gap count. How many of the nine fundamentals score 0 or 1. Those are the requirements that need a history of records, and a history cannot be compressed. Count them before you commit to a date with your certification body.
Step 3: build the slow systems first, and run them as you build
The most common plan error after the gap analysis is treating build and run as sequential, so the system is finished in month 11 and has produced three weeks of records by the audit. Every system must start running the moment it exists, even if it is imperfect. An imperfect system with eight months of records and visible improvement is far stronger at audit than a perfect system with none.
| Phase | Months | What happens |
|---|---|---|
| 1. Commit and scope | 0 to 1 | Senior management decision, scope defined, audit option chosen, certification body approached, project owner appointed with protected time. |
| 2. Gap analysis | 1 to 2 | Clause-by-clause assessment, in pairs, on the floor as well as at the desk. Output is the plan. |
| 3. Build the slow systems | 2 to 6 | Fundamentals first. HARA, training, internal audits, corrective action, specifications, traceability, cleaning. |
| 4. Build the rest | 4 to 9 | Site standards, process and print controls, personnel, traded products. Runs in parallel with phase 3. |
| 5. Run and evidence | 6 to 11 | The system operates. Records accumulate. Internal audits find things. Corrective actions close. Management review happens. |
| 6. Readiness review | 11 to 12 | Two passes: one on the floor, one at the desk. Close findings. Assemble the fundamentals evidence. |
| 7. Audit and close-out | 12 to 14 | Certification audit, then corrective action completed within 28 days. |
What is distinctive about the Packaging Materials Standard
If your experience is in food manufacturing, three parts of Issue 7 will be unfamiliar, and they are where packaging sites most often underperform.
- Artwork and print control (5.2, 5.3). There is no food-manufacturing equivalent. An incorrect allergen declaration printed on a food wrapper is a consumer safety failure created entirely by the packaging supplier, with recall potential and no later step that catches it. Formal approval must name the artwork version; plates and cylinders must be verified against the approved version before use; obsolete plates must be physically withdrawn.
- Functionality as a safety hazard. If your film has a pinhole or the seal fails, the food spoils. That is a product safety hazard caused by your packaging and it belongs in the HARA, not in a quality defect log.
- Traded products (Section 7). If you sell anything you do not manufacture, the whole of Section 7 applies: hazard analysis, approval of the actual manufacturer, specifications, testing, legality verification and an annual traceability test. Clause 7.6.3 indicates traceability should be achievable within 4 hours, or 1 day where external parties must supply information.
Do not miss P708
BRCGS position statement P708 is mandatory for audits from 10 August 2026. It adds a training requirement for the people who carry out your threat assessment (4.4.1) and requires cleaning procedures to consider disinfection and to be validated as well as verified (4.8.2). Both reach into fundamental requirements. Read what P708 changes and what to do about it.
Online, self-paced, accredited
Implementation of BRCGS for Packaging Materials Issue 7
Nine modules working clause by clause through all seven sections, built around a running case study of a South African converter. Every fundamental requirement covered in depth, knowledge checks throughout, a graded final assessment and a course assignment. Includes a downloadable implementation toolkit with all 269 Issue 7 sub-clauses pre-loaded into a gap analysis, a HARA worksheet, document register, internal audit schedule, corrective action log, glass and brittle register and traceability test record.
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Who should be trained, and on what
| Role | What they need | Which ASC course |
|---|---|---|
| Technical or quality manager owning the project | The whole Standard, clause by clause, plus how to build and evidence each system | Implementation of BRCGS Packaging Materials Issue 7 |
| Senior management | What the Standard requires of them personally: policy, objectives, culture plan, management review, and the audit opening and closing meetings | Introduction to BRCGS Packaging Materials Issue 7 |
| HARA team members | Hazard analysis principles and how Section 2 works | Introduction, then Implementation for the team leader |
| Internal auditors | The requirements they will audit against, and what objective evidence looks like | Implementation, plus internal auditor training |
| Department heads and supervisors | The sections they own: site standards, process control, personnel | Introduction as a minimum |
| Consultants and auditors | Interpretation depth across all seven sections | Implementation |
What a first audit actually looks like
An audit is a sequence of activities, not a single event: an opening meeting attended by the most senior manufacturing or operations manager on site, a review of the HARA documentation, manufacturing and storage area audits (the auditor usually enters production early and returns several times), document review, vertical audits and traceability exercises, then a closing meeting.
The vertical audit is where systems come apart. One batch is followed through everything: order, specification, raw material approval and intake, HARA controls, process records, monitoring, line clearance, print approval, inspection results, traceability, dispatch and any complaint. A weakness invisible clause by clause becomes obvious when one batch is followed end to end. Run two of these yourself before the audit.
After the audit, corrective action must be completed within 28 days, with root cause analysis and a preventive action plan. At your next audit the auditor will check that the corrective action is still in operation and that preventive action actually prevented recurrence. Submitting a revised procedure and never implementing it is the classic and expensive failure.
Five things to do this week
- Book thirty minutes with your most senior site manager. Agree who owns the project, how much of their time is protected, and that the senior manager will personally be in the audit opening and closing meetings.
- Walk your site with a camera, from the perimeter fence to the dispatch door, looking up as well as down, and open every drawer in engineering. That is most of your Section 4 gap analysis, free.
- Ask five operators three questions: what are you responsible for, where is your work instruction, and what would you do if you found something wrong.
- Score the nine fundamentals honestly from 0 to 4. The lowest scores set your audit date.
- Start the slowest thing today, usually internal audits or training, rather than when the plan is finished. The plan can catch up; the evidence history cannot.
Common questions
How long does it take to implement BRCGS Packaging Materials Issue 7?
For a site starting from no formal product safety system, 12 to 14 months is realistic for a first certification. A site with an existing ISO 9001 certificate may move faster on documentation but usually not on the fundamentals, because the evidence those require is a history of records rather than a set of procedures. What sets the earliest audit date is your slowest fundamental, not your total gap count.
What are the nine fundamental requirements in BRCGS Packaging Materials Issue 7?
Senior management commitment and continual improvement (1.1), hazard analysis and risk assessment (2.0), specifications (3.4), internal audits (3.5), traceability (3.10), corrective and preventive action (3.13), housekeeping and cleaning (4.8), manufacturing process control (5.4), and training and competence (6.1). A lack of focus on a fundamental requirement may result in certification not being granted.
How many clauses are there in Issue 7?
Seven sections containing 269 sub-clauses in total, spread unevenly: Section 4 on site standards and Section 5 on product and process control are the largest, and Section 3 on product safety and quality management contains four of the nine fundamental requirements.
Do we need a HACCP plan or a HARA?
Issue 7 uses hazard analysis and risk assessment, abbreviated HARA. The logic is closely related to Codex HACCP principles but the vocabulary differs in ways that matter: the Standard refers to critical control measures rather than critical control points. In most packaging operations very few hazards end up with a critical control measure, because there is rarely a step that eliminates a hazard. Control sits mostly in prerequisite programmes, which then have to be validated for each specific hazard under clause 2.5.4.
Does BRCGS Packaging Materials apply to a site that only stores and sells packaging?
The Standard is for manufacturers of packaging materials. If you manufacture and also sell products you did not make, those traded products are covered by Section 7, which applies in full if you include them in your certification scope. If you exclude them, they must still be controlled under clause 5.4.10 so they do not create a risk to products within scope.
What is the difference between the introduction and the implementation course?
The introduction course answers what the Standard requires and how the audit protocol works. The implementation course answers what your site must build and be able to show an auditor, working clause by clause through all seven sections with a running case study, a gap analysis toolkit and a graded assessment. Most sites send their whole team through the introduction and their technical lead through the implementation course.
Is ASC accredited, and is the certificate verifiable?
ASC Food Safety Training is SAATCA registered (TC 065) and FoodBev SETA accredited (provider 587/00337/1900). Every certificate carries a unique number and a QR code that resolves to a verification page showing the learner name, course and completion date, so an auditor or employer can confirm it against the record rather than the document in front of them.
Can we train a whole team?
Yes. ASC enrols teams in bulk, groups learners by site or department, and gives your QA or HR lead a dashboard showing who has started, who has passed and whose completion dates are approaching, with completion reports that export for your audit file. See the BRCGS certification and training hub or request a team quote.
This article is general guidance for planning an implementation project. It is not a substitute for the Standard: a site is audited against the Global Standard Packaging Materials (Issue 7) together with the position statements in force, and both the site and the auditor need an official copy. Clause numbers are given so you can navigate your own copy.