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BRC Packaging issue 5 - basic risk - 3.4.3 Declaration of Compliance

brc packaging doc 3.4.3 low risk basic risk declaration of compliance

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#1 ap87


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Posted 07 January 2016 - 03:11 PM

Hi all!


Is anyone else in this forum by chance also basic/low risk certified to the BRC packaging standard?

If so, how have you approached solving the brand new requirement of clause 3.4.3? I realize what it demands, however, this is an extremely comprehensive and time-demanding new clause that has never been required of the low risk category before. We find that it is hard to implement with such little time.


Anyone have any feedback on how they have tackled it?


Thanks a lot!




#2 Simon


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Posted 08 January 2016 - 08:37 AM

Hi Anne,

I have checked the requirements of section 3.4.3 (copied below) of the standard and they apply to both HIGH and LOW risk suppliers.  It surprised me at first.

In the classic sense a Declaration of Compliance (DoC’s) is heavily based on results of migration tests etc. and I would not expect to see migration tests as a standard on non-food contact packaging. 

Depending on the packaging and its use there may be some limited testing demanded.  For example a while ago in breakfast cereals the board was found to be migrating mineral oils though the inner bag to the cereal product.  This was because recycled materials were being used at the time to manufacture the board.  In this case you would expect the manufacturer of the cartons (printers / converters) to get confirmation from the board supplier that the board is free from mineral oils and the board manufacturer could only confirm this by migration testing.

What you need depends on your product and its intended use...non-food contact packaging can range from cereal boxes to pallets.

You should already have specifications for your raw materials.  Review (risk assess) these with your suppliers and check whether there are any legal requirements, recycled content, perhaps unknown things (very bad substances), testing that they need to do or do already.  Then amend your specifications accordingly or not at all if nothing to include.  You can call them a DoC or a specification.  It’s all the same.

That’s my take on it.  Hope it helps you.





A declaration of compliance shall be maintained which enables users of the packaging materials to ensure compatibility between those materials and the product with which they may be in contact.

The declaration of compliance shall contain as a minimum:

- the nature of the materials used in the manufacture of the packaging
- confirmation that the packaging materials meet relevant legal requirements
- the inclusion of any post-consumer recycled materials.

This shall identify any limitations of use of the product and the usable life of the packaging material (where relevant).  Products shall meet at least minimum legal requirements in the country of manufacture, and use, where known.

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