BRCGS Food Safety 5.4.5 - Regarding Gluten Free Claim

In Version 9 clause 5.4.5 states that a mass balance test needs to be performed at least every six months regarding "labelled or claims made on finished packs which are dependent on the status of the raw material..." When reading the rest of the clause, it looks to me like this is referring to claims which are via a specific scheme, like GMO Project, GFCO, etc.

 

We make products which state "Gluten Free" but it is not based on any standard other than the ingredients in the product do not contain any gluten. Would this still fall under the requirement of 5.4.5 where a mass balance must be performed at least every six months, or does it not apply to me?

 

Thanks!

Even if we were not a part of a GF certification we found that we can not rely on a supplier saying their materials were GF. We are doing our own tests and for one of our locations testing is done every day - we have already experienced the horror of finding out that a suppliers testing was bad that in turn we relied on for a label claim.

I understand what you are saying. However, my question is more specifically referring to the BRC clause and whether I am required to perform a traceability/mass balance exercise once every six months over the normal requirement of annually.

 

Thanks.

To read it plainly

 

IF you make a claim you MUST perform a mass balance every 6 months ---regardless of whether or not said claim has been verified and certified by a 3rd party

 

The only way (maybe) is IF you produced ONLY gluten free within your facility and then it would be a well written risk assessment

From the BRC interpretation guide:

"The types of claim covered by this clause relate to the provenance of ingredients used in a product that differentiates those ingredients or products from the norm...

Claims which relate to the composition of the product (e.g., nutritional claims, fat-free, reduced sugar, free-from) are covered in clauses 5.3.7 and 5.4.7."

 

I would say that gluten-free would not fall under 5.4.5.

The product I deal with are Gluten Free and Non-Gluten Free products. Gluten Free is covered under section 5.3. Not 5.4.5.

From the BRC interpretation guide:

"The types of claim covered by this clause relate to the provenance of ingredients used in a product that differentiates those ingredients or products from the norm...

Claims which relate to the composition of the product (e.g., nutritional claims, fat-free, reduced sugar, free-from) are covered in clauses 5.3.7 and 5.4.7."

 

I would say that gluten-free would not fall under 5.4.5.

 

Hi PSC,

 

I agree with Fishlady here. Your example does not fall under clause 5.4.5, you do need to validate recipe/product formulation and production processes but do not need a mass balance test every 6 months.

 

Kind regards,

 

Tony