Requirements for a raw materials Declaration of Compliance
Hi
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.
thanks
Mark
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.
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...
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.