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Requirements for a raw materials Declaration of Compliance

Declaration of Compliance in

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Posted 21 October 2020 - 01:57 PM


I wonder if anybody could shed some light on the requirements for Declaration of Compliance in raw materials. I'm preparing for an upcoming BRC audit and thought I would ensure I had all raw material DOC's. I have always been of the opinion that the DOC needed to be dated within the past 12 months. But I thought I would check it out in the regs 1935/2004 & 10/2011 as well as the BRC standard. I couldn't find anything that said the DoC needed re-issuing other than following a change. Am I ok to go into the audit with DoC's some of them dating back to 2018.





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Posted 21 October 2020 - 02:04 PM

Why do you need DOC, you're not satisfied with LOGs? That's extra work in my opinion, and I never heard of regulatory requirements to have DOCs for raw materials - unless, UK regulations require that.


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Posted 21 October 2020 - 02:14 PM

Why do you need DOC, you're not satisfied with LOGs?

LOGs seem to be more of a US-style thing - quite rare to see them used in Europe, and indeed the only time I've been asked for them is by clients in the US.



Am I ok to go into the audit with DoC's some of them dating back to 2018.

Do the DOCs include a specified period of validity? With most of the packaging materials I've used, the compliance statement will include something to the effect of a "valid for 24 months from date of issue" statement or similar.

If you don't have that then it might be worth dropping a quick note to your packaging supplier(s) just to check if the existing DOCs are still valid. Really its up to them to determine whether that is the case, although a lot of the BRC supplier/spec stuff seems to work on a period of not more than three years. It's not exactly explicit on this in the packaging standard IIRC, but it's the figure I'd expect the auditor to have in mind - as such you'll probably be ok with info dated 2018, but for the sake of a few quick calls/emails to check, I'd speak to the supplier as that is easier than arguing the point if you get one of the more pedantic auditors...

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Posted 21 October 2020 - 03:25 PM

You don't say which product type you make, but you did mention 10/2011 so I would assume it is plastics. In principle, a D of C only needs updating where there is a substantial change to the production or materials used, or if there is new scientific knowledge. When EU2002/72 changed to EU10/2011 they were OK to accept

a D of C under the old regs for up to 5 years.


But, (there always is a but) if it is plastics, there have been several amendments to EU10/2011 since 2018 and your suppliers' D of Cs need to state compliance to these newer amendments unless they are clearly not applicable.


Another potential auditor trap is if you have defined a specification review period in your system (3.4.5) and it is shorter than the time since the D of C was issued you may get an NC as D of Cs can be interpreted as specifications. Most companies seem to put in 3 years for the review so hopefully you would be OK.

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