7 replies to this topic

[gkcaduceus]

We do not utilize primary packaging (consumer packaging), and we have traceability on our food contact liners.

 

My question:

 

1.  Is secondary (non-food contact) packaging (cases & totes) subject to the traceability requirement in 3.9.3?

[mgourley]

3.9.3 specifically talks about raw materials, not packaging.

3.9.2 talks about "primary" packaging.

 

I would say the answer to your question is no.

 

Marshall

[trubertq]

I would agree with Marshall. I have never been asked for traceability on secondary packaging

[brianweber]

No it is not.

[gkcaduceus]

Thank you very much. 

[Tony-C]

As Marshall has posted the requirement is to trace primary packaging:

 

BRC Global Standard for Food Safety Issue 7

3.9.2 The site shall test the traceability system across the range of product groups to ensure traceability can be determined from raw material including primary packaging to finished product and vice versa, including quantity check/mass balance.

 

Be aware that BRC does also refer to 'any other relevant packaging'

BRC Global Standard for Food Safety Issue 7
3.9.1 Identification of raw materials, including primary and any other relevant packaging, processing aids, intermediate/semi-processed products, part-used materials, finished products and materials pending investigation shall be adequate to ensure traceability.

Example of what would constitute 'relevant packaging' is given in the BRC guideline:
BRC Interpretation Guideline Issue 7
3.9.1 The traceability system needs to include primary packaging (in direct contact with food), other relevant packaging materials (such as printed outer packaging)

 

Sleeved products come to mind.

 

Regards,

 

Tony

[MoodyVic]

In my company for "other relevant packaging materials (such as printed outer packaging)" we refer to the sales unit (for the end consumer), so we have traceability of it. 

 

But in your case i think the answer is no.

 

Isabella

 

Sorry for my English  

[Charles.C]

In my company for "other relevant packaging materials (such as printed outer packaging)" we refer to the sales unit (for the end consumer), so we have traceability of it. 

 

But in your case i think the answer is no.

 

Isabella

 

Sorry for my English  

 

Hi Isabella,

 

Thanks for yr input and Welcome to the Forum !