3 replies to this topic

[iuri]

This point of BRC states that the site must test traceability across a group of products, including primary packaging. 

So I have contacted our supplier of primary packaging to conduct a trace and they have rejected this, because they are only a wholesaler/distributor and are not willing to give details of their manufactures. the only things they are willing to share are migration reports, specifications and BRC certificate. 

 

My question is where do I stand with this / will the migration reports, specs and BRC certificate suffice? 

 

[pHruit]

3.9.3 is primarily about testing *your* traceability systems, i.e. can you achieve forwards/backwards traceability through your business and processes, for your raw materials and the packaging you're receiving/using.

 

The traceability verification requirements for your suppliers are primarily contained in clause 3.5.1.6, which has the convenient get-out clause that certification/audit may be sufficient verification. In the case of your packaging supplier I'd expect them to take the position that their own BRC certification is adequate for this, and that's perhaps not unreasonable - if the BRC standard doesn't accept BRC certification as sufficient verification then it rather undermines the whole standard

[Kara S.]

This point of BRC states that the site must test traceability across a group of products, including primary packaging. 

So I have contacted our supplier of primary packaging to conduct a trace and they have rejected this, because they are only a wholesaler/distributor and are not willing to give details of their manufactures. the only things they are willing to share are migration reports, specifications and BRC certificate. 

 

My question is where do I stand with this / will the migration reports, specs and BRC certificate suffice? 

 

 

3.9.3 is primarily about testing *your* traceability systems, i.e. can you achieve forwards/backwards traceability through your business and processes, for your raw materials and the packaging you're receiving/using.

 

The traceability verification requirements for your suppliers are primarily contained in clause 3.5.1.6, which has the convenient get-out clause that certification/audit may be sufficient verification. In the case of your packaging supplier I'd expect them to take the position that their own BRC certification is adequate for this, and that's perhaps not unreasonable - if the BRC standard doesn't accept BRC certification as sufficient verification then it rather undermines the whole standard

 

Well said pHruit. 

 

To show compliance - conducting a mock recall for a specific lot of primary packaging material is really what they are after. So you pick potential production date and pretend there was a complaints related to the packaging - then trace how much of that lot was received in, how much you still have in-house, and how much was used. 

[Tony-C]

This point of BRC states that the site must test traceability across a group of products, including primary packaging. 

So I have contacted our supplier of primary packaging to conduct a trace and they have rejected this, because they are only a wholesaler/distributor and are not willing to give details of their manufactures. the only things they are willing to share are migration reports, specifications and BRC certificate. 

 

My question is where do I stand with this / will the migration reports, specs and BRC certificate suffice? 

 

Hi iuri,

To add to the posts above, is your supplier certified to BRC? This is the most important thing.

Ideally both your supplier and the manufacturer would be BRC certified (or an equivalent GFSI benchmarked standard).

Your supplier should also be able to give you details of the packaging and batches/quantities they have supplied for your traceability test.

Kind regards,

Tony