Hi. There was an update email from BRC clarifying the vulnerability requirement for the BRC Food Standard as some food packing companies have misinterpreted this requirement to include packaging. I have copied the relevant section of the email below. As you say, this is not part of BRC Packaging.
Clarification of Clause 220.127.116.11
Analysis of the audit data has highlighted that Clause 18.104.22.168 may be misinterpreted. This clause includes the requirement for sites to ‘take into account the potential for substitution and fraud’ (see Clause 5.4.2). The purpose of this reference is to highlight that supplier approval processes must include consideration of any risks highlighted during the vulnerability assessment, such as those identified when completing activities for Clause 5.4.2.
Clause 5.4.2 clearly states that it is only relevant to food raw materials (it does not cover packaging raw materials, so we do not expect supplier approval processes for packaging materials to include an assessment for substitution or fraud). All other requirements of Clause 22.214.171.124 apply to all raw materials (both food and packaging raw materials).