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BRC 5.2 Product Labeling - HELP!

BRCProduct Labeling Verification BRC 5.2 Version 8

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#1 aab93

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Posted 02 August 2019 - 11:51 PM

Hello IFSQN community, 

 

I am reaching out to you all to ask about how, those of you who are BRC Version 8 certified, are handling the label verification activities required under BRC Clause 5.2 (Version 8). Specifically, with clause 5.2.4 which states that "Where the label information is the responsibility of a customer or a nominated third party, the company shall provide information: to enable the label to be accurately created, whenever a change occurs which may affect the label information."  

 

How exactly do I show compliance with customer-prescribed labels and what forms of verification are really needed? My original assumption is regulatory related items should be verified and that is currently what I am checking (IE; accuracy of weight calculations listed on packaging, ingredient listing, and the presence of allergen declarations as they apply, etc.). Any other ideas? Also, does this verification activity only have to apply at initial product rollout or should it be verified with each production? 

 

Any advice would be much appreciated!  :blink:



#2 atifengineer2008

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Posted 03 August 2019 - 09:39 PM

Please see the attached file ,may be it help you

Attached Files



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#3 pHruit

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Posted 05 August 2019 - 08:31 AM

 

How exactly do I show compliance with customer-prescribed labels and what forms of verification are really needed? My original assumption is regulatory related items should be verified and that is currently what I am checking (IE; accuracy of weight calculations listed on packaging, ingredient listing, and the presence of allergen declarations as they apply, etc.). Any other ideas? Also, does this verification activity only have to apply at initial product rollout or should it be verified with each production? 

 

How do you currently manage this process?
In cases where we are using customer's labelling, we go through the same product development and sign-off process, but with extra countersignatures from the client - this includes the recipe form (detailing composition and nutritionals) and the full product specification. The countersignatures on these demonstrates that they have been provided with and agreed the key information for label dec, ingredient list, nutrition panel, allergens etc.

As we print the labels on site, once the spec has been agreed we also send them a copy of the label for review, and won't go into production with their product until this we have had a signed copy returned to confirm their approval.

For the "changes" aspect, we'd handle this as per section 5.1, so a modification to formulation or similar goes back into the development process for HACCP review, trials etc as required, and that also re-initiates the requirement for customer sign-off, again demonstrating that they've been provided with and agreed the new information.



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#4 aab93

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Posted 05 August 2019 - 03:20 PM

How do you currently manage this process?

 

We have a product roll-out and during that process a sample of the label is provided for review where regulatory compliance is the main focus - dependent on what the product is used for (IE; sale to the end consumer versus packed for further processing) I will review that there are certain components present on the label - IE; product name, ingredient list, nutritional panel (applicable to sale to final consumer), allergen declaration (if applicable), Country of Origin, net weight, nutritional claims and verification of any third-party certifications included on the label. However, what happens often with one particular customer is that they change their ingredient supplier which affects the certifications and Country of Origin (IE; if they don't source fair trade ingredients, the fair trade logo will not be listed). My concern is that, if any other areas were to change (IE; cooking instructions, nutritional facts, etc;) would it really need to be up to me to catch these changes and bring it to the customer's attention or can I simply fall back on the fact that the label was customer-prescribed and they should know what is on the label ?



#5 pHruit

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Posted 05 August 2019 - 03:41 PM

Ok, understood. It sounds like the customer flitting between sources like that could also create some headaches for supplier approval?

 

In terms of the label bits in 5.2.4, I only have direct experience of the case where we are making changes that affect the label, but to an extent that is also my reading of the clause and the interpretation guide: "A system must therefore be in place to transfer all relevant information to the customer and for ensuring that any changes are communicated in a timely manner".

 

Are you printing the labels on site / responsible for commissioning and purchasing the labels?
If so, you might arguably find yourself in the reverse situation, where the accuracy of the labels could be compromised by a lack of timely communication of changes from the customer to you. Perhaps a brief written agreement signed by them to confirm that they will notify you in advance of any pertinent changes?

 

 



#6 aab93

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Posted 05 August 2019 - 05:20 PM

Ok, understood. It sounds like the customer flitting between sources like that could also create some headaches for supplier approval?

 

We have different vetting standards for our supplier approval program when it comes to customer-prescribed ingredients - overall our customers do not provide us with transparency into their supply chain (and frankly we don't want the headaches of managing their supply chain either) and so we don't ask too much about that. We primarily provide the service of cleaning product and co-packing according to our customer's request/specifications. 

 

Are you printing the labels on site / responsible for commissioning and purchasing the labels?

If so, you might arguably find yourself in the reverse situation, where the accuracy of the labels could be compromised by a lack of timely communication of changes from the customer to you. Perhaps a brief written agreement signed by them to confirm that they will notify you in advance of any pertinent changes?

 

Yes, we print labels on-site - the customer provides us with a PDF file of their label and we print them on blank label sheets. 

What you just expressed is exactly the issue that come across... we do have our customers sign an indemnity release that states that its ultimately up to the customers to ensure their labels are accurate. However, our QC staff runs the labels through a fine tooth comb and any discrepancy between the new label and the previously approved label provided by the customer is noted. 



#7 QAGB

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Posted 05 August 2019 - 06:42 PM

We have different vetting standards for our supplier approval program when it comes to customer-prescribed ingredients - overall our customers do not provide us with transparency into their supply chain (and frankly we don't want the headaches of managing their supply chain either) and so we don't ask too much about that. We primarily provide the service of cleaning product and co-packing according to our customer's request/specifications. 

 

 

Yes, we print labels on-site - the customer provides us with a PDF file of their label and we print them on blank label sheets. 

What you just expressed is exactly the issue that come across... we do have our customers sign an indemnity release that states that its ultimately up to the customers to ensure their labels are accurate. However, our QC staff runs the labels through a fine tooth comb and any discrepancy between the new label and the previously approved label provided by the customer is noted. 

 

It seems to me that you are doing all the right things. If your customer isn't supplying you with transparency, then you have to rely on the information they give to you. If you are doing any additional blending or have processes which would alter any of the information on the label, it would be your responsibility to make sure that the label is accurate to meet their processes and yours. For example, if you produce product on an allergen containing line and you choose to offer a disclaimer per company policy, then you need to be sure to add this disclaimer to the label and get customer approval as well.

 

The fact that you are vetting the labels tells me that you are also further following processes by ensuring accurate information. If you don't already have the process in writing as you have described it here, I would suggest you do that. I feel that your checking the labels is proof that you are confirming as much about the label as you can. Obviously if there is processing upstream of you, and they aren't transparent about those processes, you can't know all there is to know about the information on the label. However, if you do get wind of regulatory changes that could affect your products, you are responsible to make sure your customer is aware of these changes and to make sure the labeling meets the proper standards. 

 

This is one of the clauses in BRC that annoy me, because this really only makes sense for people who totally manufacture their own product and provide private-label product to other customers. This doesn't really make sense for manufacturers that co-pack for other companies, and don't own the formulas. If you are provided with a pre-mix of proprietary (%) ingredients, you can't know all there is to know about the labeling. You can do your best to provide accurate information from your processing point only. 



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#8 aab93

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Posted 05 August 2019 - 08:41 PM

This is one of the clauses in BRC that annoy me, because this really only makes sense for people who totally manufacture their own product and provide private-label product to other customers. This doesn't really make sense for manufacturers that co-pack for other companies, and don't own the formulas. If you are provided with a pre-mix of proprietary (%) ingredients, you can't know all there is to know about the labeling. You can do your best to provide accurate information from your processing point only. 

 

Thank you QAGB - I absolutely agree with you on ^this point!!

As for the rest of your response, thank you for clarifying more and for putting it into perspective with the allergen-declaration example. I guess from a regulatory standpoint, would you think that it is still necessary for me to continue reviewing the label? And if I find a non-conformity, I inform the customer and they can choose whether or not to proceed? 



#9 QAGB

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Posted 06 August 2019 - 02:17 PM

Thank you QAGB - I absolutely agree with you on ^this point!!

As for the rest of your response, thank you for clarifying more and for putting it into perspective with the allergen-declaration example. I guess from a regulatory standpoint, would you think that it is still necessary for me to continue reviewing the label? And if I find a non-conformity, I inform the customer and they can choose whether or not to proceed? 

 

Hi aab93,

 

Yes, I think you should continue reviewing the label and notifying the customer of any non-conformities. Reviewing the label is how you show you are compliant with the clause, and is important regulatory wise as well. As you are applying labels to product, you have to be sure that the information you are applying is as accurate as you can provide.







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