BRCGS Clause 7 traded goods - voluntary?

Hi all,

The FAQ section of the BRC website for the packaging standard states that Clause 7 for traded goods remains voluntary. As such I would guess that this isn't included as an exclusion to scope. This isn't outlined very clearly by the BRC however, as what happens for a site that does deal with traded goods, yet chooses not to be audited to this voluntary clause, does it count as an exclusion or not? At our most recent audited I pointed my auditor to this document and he accepted my reasoning that it shouldn't be classed as an exclusion, but it didn't seem very robust and even he wasn't sure what the official line on this was. Any ideas/experiences you;ve had with this would be appreicated.

Thanks.

Hi paulkenny92,

Your traded products will need to be an exclusion if you don’t want to them to be part of the audit/certification.

BRCGS Key changes to the requirements for Issue 6 states:

Traded products

Issue 5 introduced a traded goods module for sites that store and sell food and/or non-food consumer products that are not manufactured, processed or packed on site. Issue 6 has incorporated these requirements into the main text of the Standard (section 7). This has the advantage of locating the text within the main document, thus allowing the module to be accredited at the same time as the rest of the Standard.

BRCGS Global Standard for Packaging Materials Issue 6 Interpretation Guidance for Section 7 Requirements for traded products

Where a site purchases and sells packaging products that would normally fall within the scope of the Standard and are stored at the site’s facilities, but which are not manufactured, further processed or packed at the site being audited, the site’s management of these products shall be covered by the requirements in this section.

Have a look at BRCGS Global Standard for Packaging Materials Issue 6, Section 1.6 Scope of audit - 1.6.2 Exclusions from scope

The BRCGS logo can only be used by sites that have no exclusions. The exclusion of products produced at a site will only be acceptable where:

• the excluded products can be clearly differentiated from products within scope and

• the products are produced in a physically segregated area of the factory.

Products purchased for resale by a site (i.e. traded products) can form an agreed exclusion and therefore the requirements of section 7 (Part II) will not be applicable. It should be noted that the BRCGS logo cannot be used for promoting traded products even when they form part of the certificated scope.

Kind regards,

Tony