Section 5.3 of BRC v6

Hi

I need a little help please?

We buy in non GMO soya lecthin which comes with a non GMO cert from the supplier who have been audited by cert id.

we use amounts in a popcorn recipe.

is this section applicable to us? do we need to do a mass balance every 6 months for the soya lecithin?

thanks

Whitney

Is that the identity preserved bit?  It's a vague section I know but deliberately so because it's meant to cover loads of claims.  For that GMO free claim, if that's the only lecithin you use, then I don't think it applies, perhaps do a quick audit of your supplier's controls but do bear in mind if you make other claims, e.g. "British" or "vegetarian" then this section may still apply!

Hi

 

I need a little help please?

 

We buy in non GMO soya lecthin which comes with a non GMO cert from the supplier who have been audited by cert id.

 

we use amounts in a popcorn recipe.

 

is this section applicable to us? do we need to do a mass balance every 6 months for the soya lecithin?

 

thanks

 

Whitney

Hi Whitney,

I think you are referring to section 5.3 Provenance, assured status and claims of identity preserved materials (Section 6.3 is Calibration and control of measuring and monitoring devices).

The question in this case is whether you are making a claim of GMO free or not.

If you are making a claim then the following applies:

BRC Guidance 5.3.2 Traceability - Full traceability must be maintained as per clause 3.9. In the absence of scheme requirements the site must undertake at least every 6 months a mass balance traceability test.'
 

Regards,

Tony

Hi, yes sorry i mean 5.3! when you say make a claim, do you mean on the pack? We dont state it on the pack but we complete customer specs and state that the products are GMO free on the specs. is that classed as a claim?

thanks

Whitney

_Hi

 

_{yes sorry i mean 5.3! when you say make a claim, do you mean on the pack? We dont state it on the pack but we complete customer specs and state that the products are GMO free on the specs. is that classed as a claim?}

 

_thanks

 

_Whitney

Hi Whitney,

If you put it in the product specification then as far as I'm concerned that is a 'claim'

Regards,

Tony

Agree with Tony-C. If you state it anywhere in public information it is a claim. Don't forget that any product information that you publish on your food business website. There were a couple of recent prosecutions around false and misleading claims here in Australia where a food company was fined for claims also made on their website (not just the product packaging).

On the traceability / mass balance exercise, you need to be able to trace all ingredients (including quantity check/mass balance) regardless of claims made in accordance with BRC 3.9 Traceability. 

Cheers

Amanda

If it's in your specs then it's a claim, however, if all of your lecthin is GMO free, you could record that somewhere in a risk assessment for not doing it, however, there are very few auditing standards nowadays that don't require mass balance somewhere so it's probably worth doing some practice ones anyway.

Btw, all that's required is a traceability audit every 6 months including mass balance; you don't need to mass balance all of the lecithin over 6 months.

Thanks Everyone for your help :happydance: