BRC 8 requirements for co-packers

Our site is BRC certified. We have several co-packers that packs products for us. Our team is confused regarding which BRC bullets applies in our BRC program with regards to co-packed products?

 

Thanks.

 

 

Hi J T,

 

It is quite confusing, please clarify what operation the co-packer is performing? Is it co-manufacturing or is it final packing and she the product return to you before distribution to customer?

 

Kind regards,

 

Tony

Hi Tony,

 

These are companies that manufactures finished product under our brand name. We generally supply one ingredient whereas most other ingredients and packaging are directly sourced by them.  Products are processes/ packed as per agreed upon specifications. We receive finished product from them and we sell as per customer orders.

 

Thanks.

JT,

Are there bullets that you are trying to decide between in regards to your facility and BRC? Generally speaking when dealing with a copacker you need to ensure theat they have approved FSP processes in place as well. Often times they do and you can reference them in your program to ensure that they arent falling short and putting your product at risk at any point. You want your plans to seamlessly integrate and flow in line with your copacker and then to the final destination. You dont need to create the FSP for them but it should be documented, as well as a way to ensure that they are following their own FSP (either through an onsite audit or other means).

does bullet 9 apply in this case?

Hi J T

 

I would treat them as per the section 3.5.4 MANAGEMENT OF OUTSOURCED PROCESSING AND PACKING but also note they should be BRC certified:

 

3.5.4 MANAGEMENT OF OUTSOURCED PROCESSING AND PACKING

Where any process step in the manufacture or packing of a product which is included within the scope of certification is subcontracted to a third party or undertaken at another site, this shall be managed to ensure it does not compromise the safety, legality, quality or authenticity of the product.

Interpretation Guideline:

Where a product is entirely manufactured at a separate site (i.e. where co-manufacturing occurs) rather than just part of the manufacturing process being outsourced, this is not covered by these requirements as the expectation is that each individual site will be certificated.

 

​This will not be in your scope of certification but you should ensure that adequate controls are in place.

 

Kind regards,

 

Tony

Hi Tony,

 

you mentioned "should ensure that adequate controls are in place" with that is it auditable being out of scope?

 

In our case all sites are GFSI certificated and we have written contracts and specifications. We have monitoring as well i.e. up to date Letter of Guarantee, audit certificate and report, micro testing at predetermined frequency etc. but these docs are not auditable i.e. not doc controlled.

 

Last year our auditor excluded being out of scope however this year our team thinks all these now becomes part of bullet 9 (traded products). Please advise.

 

Thanks.