It seemed a little too suspicious so after further digging I did find this from the BRC website: https://www.brcgloba...p-and-guidance/ Near the bottom of the page there are 3 "Position Statements" P552 appears to include Food Defense and Food Fraud as included in audits as of the issue date:
Food Fraud
Definition used in the BRC Global Standard for Food Safety
“Fraudulent and intentional substitution, dilution or addition to a product or raw material, or misrepresentation of the product or material, for the purpose of financial gain, by increasing the apparent value of the product or reducing the cost of its production.”
Definition used in GFSI benchmarking Issue 7
“A collective term encompassing the deliberate and intentional substitution, addition, tampering or misrepresentation of food, food ingredients or food packaging, labelling, product information or false or misleading statements made about a product for economic gain that could impact consumer health.”
Application in the packaging industry
Again, a risk assessment approach will help sites in determining if there is opportunity in their supply chain, raw materials management and processes for fraudulent activity to take place.
Potential sources of fraud for the packaging manufacturer include:
- Fraudulent raw materials, e.g. non-FSC board/pulp sources in place of FSC board.
- Downgrading or substituted product, e.g. selling recycled board as virgin.
- Packaging which has been bought by non-genuine people, e.g. buyer purporting to be from a brand owner.
The potential hazards affecting brand owners that packaging manufacturers can help to mitigate include:
- Genuine packaging which is misappropriated for fraudulent products, where excess printed packaging has been illegally obtained and is essentially indistinguishable from genuine products.
- Fraudulent packaging which has been printed with genuine branding/artworks, where the brand logo has been obtained and is being used on fraudulent products.
- Misrepresentation of the retailed product, i.e. fraudulent packaging and a fraudulent product retailed as a genuine product.
Two of these three points can be affected by the packaging manufacturer. For example, if the management of excess printed packaging materials is effective, ensuring that it is not possible for these types of materials to be used, then the risk of this scenario is reduced.
Similarly, where the site has proper control of logos and branding that has been given to them in order to print or decorate packaging materials, the likelihood that these can be obtained and mis-used by unauthorised parties.
Requirements in 4.10 – Waste and waste disposal, 5.2 – Graphic design and artwork control, 5.3 – Packaging print control, and 5.7 – Control of non-conforming product are all relevant as they contain requirements outlining the site’s responsibilities with regards to management of digital data, such as logos, control of printing plates and other decoration media, and management of excess materials and non-conforming (but useable) materials. This is not just with regards to physical items, digital security is crucial so sites should be investigating their systems vulnerabilities.
When auditing these clauses, BRC expectation is that the assessment shall result in a plan to manage the identified hazards associated with raw materials or groups of materials. This will include:
- The identification of the measures to reduce the risk
- Implementation of the identified processes to manage the risk
- Testing and assurance processes (monitoring) where applicable is effectively applied
- Corrective and preventative actions where testing or checks indicates failure
- Annual review of the assessment (plan) for effectiveness.
These changes should be included as part of audits from the date of issue of this document. However, it is not expected that non-conformities shall be raised until July 1st 2018.
