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BRC Packaging Materials Scope


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Carolina S.

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Posted 10 November 2020 - 10:16 AM

Hi all

 

I am implementing the BRC Packaging Materials standard and I am currently defining the scope. 

There are products that we don't have much interest that are included in the scope because there are commercialized products.

However I am not sure if I am interpreting correctly what the standard mentions about exclusions. 

It mentions:

 

"The excluded products can be clearly differentiated from products within scope"- This diferrentiation is about what ? Composition, visual appearance, aplication?

 

Basically I have a product that will be commercialized, it doesn't suffer any manipulation from us. As it comes it goes to the client. And the own packaging of the product refers who is the supplier. 

 

However, this product at visual level, composition and application is not different from other products that we produce and that will be included on the scope. 

 

Can anybody help me?

 

Thanks in advance.

 



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Posted 10 November 2020 - 12:07 PM

You can exclude it from scope and simply note that in the facility.

 

Areas where exclusions are stored/produced at still subject to inspection.


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Foodworker

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Posted 11 November 2020 - 06:47 PM

If I understand correctly, these products are not made on your site and are sold under a different company's name so I would argue that they can be clearly be differentiated and can therefore be excluded.

 

If you want to add more work for yourself you could look at including traded goods in the scope but I wouldn't unless it makes up a large part of your overall business.



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Carolina S.

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Posted 12 November 2020 - 09:20 AM

Thank you very much for your replies!

 

I am quite confused about this issue. 
I have people who say that products that I don't produce on the site can be excluded from the scope or include using chapter 7- Requirements for traded goods.
Other people say I have to see if the products I buy for resale are differentiated from the products I produce. If they are not, I cannot exclude them from the scope. 

Here is an example:

 

In the site we produced vacuum bags. But we also buy vacuum bags to then sell by our name. These bags are not manipulated. The labels on the boxes where the bags are placed already come from the supplier identified with our name. 
 
These bags are traded goods but they are not clearly differentiated from the bags that I produce. Can or cannot exclude these products ?


Charles.C

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Posted 12 November 2020 - 10:08 PM

Hi Caroline,

 

In addition to previous useful inputs, queries like this can often get free, appropriate responses from yr usual CB auditor because they have to know the answers for auditing purposes.


Kind Regards,

 

Charles.C


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beautiophile

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Posted 13 November 2020 - 01:19 AM

 

Thank you very much for your replies!

 

I am quite confused about this issue. 
I have people who say that products that I don't produce on the site can be excluded from the scope or include using chapter 7- Requirements for traded goods.
Other people say I have to see if the products I buy for resale are differentiated from the products I produce. If they are not, I cannot exclude them from the scope. 

Here is an example:

 

In the site we produced vacuum bags. But we also buy vacuum bags to then sell by our name. These bags are not manipulated. The labels on the boxes where the bags are placed already come from the supplier identified with our name. 
 
These bags are traded goods but they are not clearly differentiated from the bags that I produce. Can or cannot exclude these products ?

 

As Charles said, it's a good idea to ask CB about the scope. AFAIK, the certificate belongs to the CB, a certified company is just nominated on it. Hence, they will probably take care of that.

BTW, do your products have your own processing traceability codes (example: printed on the gazette or bottom) and the traded one don't? If so or another method of traceability (clause 3.11.3), I think the differentiation is possible.


Edited by beautiophile, 13 November 2020 - 01:19 AM.


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john.kukoly

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Posted 13 November 2020 - 12:56 PM

The BRCGS Standards allow exclusions only where the product is clearly different from those products included. As an example, you can't exclude organic broccoli but include non-organic broccoli.

 

I always caution a site to consider before excluding. Anything listed as an exclusion in an audit report or on a certificate, is usually a big red flag for customers - their concern is that some site processes are substandard and had to be excluded. In reality, a site at times tries to exclude simply as a reaction. bringing an entire operation under certification is valuable, everyone knows this. Think about why you are wishing to exclude the product, and challenge why it can't be included. 

 

There are times where a valid reason exists to exclude some processes, but in reality very rate, and should be considered only with caution.

 

The way you described it Carolina, this would fall into our definition of "Traded Goods". Yes, they can be excluded if you feel the need. The best advice above is true, talk to your certification body about it, or of course, ask the BRCGS team......

 

John



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Foodworker

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Posted 14 November 2020 - 11:24 AM

Your second example is different from the first that you gave.

 

They are very similar to products that you manufacture and critically,you are selling them under your own name.

 

The reason that there are rules about exclusions is to enable purchasers to clearly understand which products have been made in accordance with the BRC's Standard and which have not. As your certificate will state vacuum bags it will be difficult for a purchaser to know that not all vacuum bags have been made in a 'BRC' factory. (Your supplier may or may not be certified, we don't know, but it is your certificate)

 

As previously posted, you will need to confirm the products with your CB.

 

If you have a lot of products which are made for you including the Traded Goods module may be the best option. It is relatively easy but only if you use suppliers which have good systems in place.



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Carolina S.

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Posted 16 November 2020 - 08:45 AM

As Charles said, it's a good idea to ask CB about the scope. AFAIK, the certificate belongs to the CB, a certified company is just nominated on it. Hence, they will probably take care of that.

BTW, do your products have your own processing traceability codes (example: printed on the gazette or bottom) and the traded one don't? If so or another method of traceability (clause 3.11.3), I think the differentiation is possible.

For the products that are produced, we have our own batch number assignment system. It is placed only on the label. 
For the traded goods we take the lot from the supplier.   


Carolina S.

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Posted 16 November 2020 - 08:49 AM

Thank you all for your answers!
 
This will be the first certification audit of the company. And it is also the first time that I go through a certification process. 
In this first audit we would opt to exclude some products just because they are sold with the name of the manufacturer (which is not us). 
 
The idea of clarifying this issue with the certification body makes perfect sense, But I haven't chosen a certification body yet. Maybe it will be my next step. 


Charles.C

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Posted 17 November 2020 - 07:45 AM

 

Thank you all for your answers!
 
This will be the first certification audit of the company. And it is also the first time that I go through a certification process. 
In this first audit we would opt to exclude some products just because they are sold with the name of the manufacturer (which is not us). 
 
The idea of clarifying this issue with the certification body makes perfect sense, But I haven't chosen a certification body yet. Maybe it will be my next step. 

 

Hi Carolina,

 

Yes it probably should.

 

I suggest you also consider the opportunity for requesting the chosen CB to do a preliminary "mock"  audit.


Kind Regards,

 

Charles.C


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