BRC 8 : primary packaging VS. secondary packaging

Our customers are industrial, food service and retails; the product sold to our industrial customer is packed on blue liner plastic then cartons; those cartons are gathered on pallets and wrapped by a plastic wrap. And we are confused what to consider primary and secondary packaging. My questions are :

-     According to the BRC definition of primary packaging what the unite of sale really mean?  is it what the final customer receive “consumer” or what the industrial and food service customer receive?

-     In our case, I consider carton is primary packaging as it’s part of the unite of sale but there were lot of discussion about that as it’s sold to an industrial and some doesn’t see the necessity to evaluate and approve the supplier of the carton. What is the right way to ensure the compliance with the BRC requirement?

We are a contract packager and consider food contact packaging as primary. If it touches the food, it's primary. All other packaging, ie cartons, is secondary, tertiary, etc.

 

-     In our case, I consider carton is primary packaging as it’s part of the unite of sale but there were lot of discussion about that as it’s sold to an industrial and some doesn’t see the necessity to evaluate and approve the supplier of the carton. What is the right way to ensure the compliance with the BRC requirement?

 

I think you are right. At the vantage point of packaging manufacturers, the cartons are certainly the primary package. But at the food makers, those cartons will be waste (they may not use them at all). They can buy new from their own carton suppliers as secondary packaging. And your products (direct food contact) are primary.

However, you still have to ensure your cartons don't contaminate or cast a high risk of food safety on your products. 

From BRC8 -

Primary packaging - The packaging that constitutes the unit of sale to the consumer or customer (e.g. bole, closure and label of a retail pack or a raw material bulk container).

Secondary packaging Packaging that is used to collate and transport sales units to the retail environment (e.g.corrugated case).

Personally I would have picked Post 2's answer to the OP to be the logical one but BRC seem to require to go it  "their way".

I agree with the first reply. I worked for a company that produces both primary and secondary packaging.

Primary packaging is the one that touches (or with direct contact) with the food.

Secondary packaging is the one that "covers" or is outside of the primary packaging.

Example, a box of cereals:  The sealed plastic that contains the cereals itself is the Primary Packaging.

The cereal BOX made of corrugated carton is the Secondary Packaging.

Any packaging with direct contact with food is primary packaging.
​Even if it is only used , for example, to transport the food from one area to another, then removed or discarded upon arrival, only to be replaced by another primary package.

Hope this is helpful.

I agree with the first reply. I worked for a company that produces both primary and secondary packaging.

Primary packaging is the one that touches (or with direct contact) with the food.

Secondary packaging is the one that "covers" or is outside of the primary packaging.

Example, a box of cereals:  The sealed plastic that contains the cereals itself is the Primary Packaging.

The cereal BOX made of corrugated carton is the Secondary Packaging.

 

Any packaging with direct contact with food is primary packaging.
​Even if it is only used , for example, to transport the food from one area to another, then removed or discarded upon arrival, only to be replaced by another primary package.

 

Hope this is helpful.

So you also don't agree with BRC ? Unfortunately it's their Code. :smile:

From BRC8 -

 

 

 

Personally I would have picked Post 2's answer to the OP to be the logical one but BRC seem to require to go it  "their way".

I tend to agree with you Charles.

BTW the definitions are the same in BRC Global Standard for Packaging and Packaging Materials Issue 5:

Primary packaging - That packaging which constitutes the unit of sale, used and disposed of by the consumer (e.g. bottle, closure and label).
Secondary packaging - Packaging that is used to collate and transport sales units to the retail environment (e.g. corrugated case).

In this case the product is clearly the primary packaging and everything else is secondary packaging.

Kind regards,

Tony

BRC Definition of Primary is everything the final consumer will have, so in the case of cereal, it would be the Plastic bag the cereal is in and the cardboard box also. With regards to B2B, if you were supplying in buckets, it would be the bucket liner, the bucket, the lid, the handle and the label would be deemed as Primary in the eyes of BRC. However the pallet it is delivered on and the pallet wrap to hold it on would be secondary. Which is different to previously as it would of been just the plastic bag in the cereal and the bucket liner before. Hope that makes sense. 

Hi all, and Happy New Year.

Yes, just like the term "high risk" BRC has put their own unique definition to a fairly common industry term - "primary packaging". Arguably a more unique term could have been used. The BRC definition, applied only to those facilities intending to undergo BRC certification, is in the standard, relatively clearly. That being said, I always encourage sites to look at the intended outcome, before worrying too much about the definition debate. In previous versions, there is the generic term "packaging" - then you look at a specific requirement and the endless debate about which pieces of packaging us that clause relevant to... one of the most debated was traceability. This gives much clearer direction, which I do appreciated. 

If you go through the 8th issue of the Standard, here is where the term "primary packaging" comes into play - and which clauses you can now see apply (to things like food contact packaging) and which don;t apply (typically things like shrink wrap on the outside of a pallet, or a pallet license plate).

What applies to "primary packaging"?

3.5 having an effective supplier approval program

3.5.1.1 perform a risk assessment on it as a raw material

3.5.1.2 create an effective supplier approval mechanism based on the risk assessment

3.5.1.5 do the same if you purchase the materials from a broker

3.5.1.6 ensure the supplier has a traceability program

3.5.2 have an effective, risk based receiving and acceptance program

3.6 have specifications for it

3.9 the site being certified needs to have some form of traceability on the materials

4.7.5 maintenance materials coming into contact with the materials should be approproate

5.5.1 potential product / package interactions or needs should be identified

Looking at the list, which is really just basic supplier management, you can see how using the definition gets the right material into a proper management system.

Hi all, and Happy New Year.

 

Yes, just like the term "high risk" BRC has put their own unique definition to a fairly common industry term - "primary packaging". Arguably a more unique term could have been used. The BRC definition, applied only to those facilities intending to undergo BRC certification, is in the standard, relatively clearly. That being said, I always encourage sites to look at the intended outcome, before worrying too much about the definition debate. In previous versions, there is the generic term "packaging" - then you look at a specific requirement and the endless debate about which pieces of packaging us that clause relevant to... one of the most debated was traceability. This gives much clearer direction, which I do appreciated. 

 

If you go through the 8th issue of the Standard, here is where the term "primary packaging" comes into play - and which clauses you can now see apply (to things like food contact packaging) and which don;t apply (typically things like shrink wrap on the outside of a pallet, or a pallet license plate).

 

What applies to "primary packaging"?

 

3.5 having an effective supplier approval program

3.5.1.1 perform a risk assessment on it as a raw material

3.5.1.2 create an effective supplier approval mechanism based on the risk assessment

3.5.1.5 do the same if you purchase the materials from a broker

3.5.1.6 ensure the supplier has a traceability program

3.5.2 have an effective, risk based receiving and acceptance program

3.6 have specifications for it

3.9 the site being certified needs to have some form of traceability on the materials

4.7.5 maintenance materials coming into contact with the materials should be approproate

5.5.1 potential product / package interactions or needs should be identified

 

Looking at the list, which is really just basic supplier management, you can see how using the definition gets the right material into a proper management system.

Hi John,

Some of the reasons for this, probably, contentious BRC innovation are detailed/argued over in this recent article -

https://techni-k.co....mary-packaging/

BRC8,primary packaging, dec.2018.pdf   718.18KB   229 downloads

Looks like this one is not going to go away any time soon.

PS - I presume GFSI has no particular opinion on this matter.

Thanks Charles. Kassy knows her stuff well, appreciate pointing out that discussion.

My main point was about making the "what" clear, and then looking at what it really means for sites. I am not sure I always fully understand the "why" behind some things.

BRC Definition of Primary Packaging-

" The packaging that constitutes the unit of sale to the consumer or customer (eg. bottle, closure and label of a retail pack or a raw material bulk container."

BRC Definition of Primary Packaging-

 

" The packaging that constitutes the unit of sale to the consumer or customer (eg. bottle, closure and label of a retail pack or a raw material bulk container."

= Post 4 ??

No one has defined "customer" for original poster and it looks like that has also contributed to the confusion

Customer= who ever YOU sell the product to (remove the word consumer from your vocabulary in this case) regardless of whether it's in bulk cases, or totes or whatever the case may be

I'm wondering is BRC has included the carton and label due to labeling issues?????? Sometimes cartons are preprinted and there could be errors there

Sure enough, i did not see the verbage. My apologies

Sure enough, i did not see the verbage. My apologies

No problem. It's worth repeating.

The BRC says this about primary packaging; "There are numerous examples of migration from packaging other than food contact (e.g. from inks used on external labels). It is therefore important that the site considers the potential risk from all primary packaging,and addresses this in consultation with its packaging supplier(s)."

The BRC says this about primary packaging; "There are numerous examples of migration from packaging other than food contact (e.g. from inks used on external labels). It is therefore important that the site considers the potential risk from all primary packaging,and addresses this in consultation with its packaging supplier(s)."

Hi Hank Major,

Thks yr input.

Yes, this is "discussed" in the link given in Post 10.

Thank you all guys those discussions clarify The BRC requirements :thumbup:

Dear,

If 12 pineapple cans packed in the corrugated box/case, then the company sells in 2 ways, one is the retail sale (each 12 can on shelf) and another is the wholesales (12 cans in corrugated box on shelf). For the wholesales, what the primary packaging is, other than tin can and label? is the corrugated box, the primary packaging?

KK

How is everyone dealing with traceability of the new primary packaging (labels, thread -for sewn paper bags, etc.) We already have a traceablity program in place for our food contact packaging like bags and totes. But now to have to be able to trace the labels that come plain with no lot? 

If your labels do not have a lot (and they usually have something on them to indicate the product run) you could

A) ask the manufacturer to add one

B) mark boxes with the date you received them and use that date for traceability

C) generate a lot upon receipt and use that

Thread you could do the same, the difference is you'd need to know ~how much is used per unit

If your labels do not have a lot (and they usually have something on them to indicate the product run) you could

 

A) ask the manufacturer to add one

 

B) mark boxes with the date you received them and use that date for traceability

 

C) generate a lot upon receipt and use that

 

Thread you could do the same, the difference is you'd need to know ~how much is used per unit

In my opinion, point B and C is the easiest way to do this, but if we check the 3.5.1.6 about every supplier for raw material and primary packaging shall have an "effective traceability system" then what's the point we mark our own date or lot if the supplier can do the traceability. The supplier should have their own lot or code in order to fulfill the traceability.