Origin of raw materials, Clause 2.2.3 BRC issue 6.

Dear Sir and Madam. We have some doubts how to make description according to a clause 2.2.3: exempt: “origin of raw materials, including use of recycled materials”. How should it be? Should it include origin country of each of the components or type of product (organic, mineral etc.), type of manufacture process? etc? For example: we may try out to describe a laminated polymer film with some printing. This product includes a lot of components: a film, an ink, a lacquer, an adhesive, some additives, retention solvent in layer. We’re looking forward to your advices. Thanks for advance Have a nice day 😊

I doubt it, I think it means YOUR use of recycled materials

This clause is essentially the starting point of your hazard analysis so understanding what the product is, what it is made of and how it is to be used should help you work out what potential hazards there may be.

For instance in your example, it may be a food contact laminate. If the food contact layer is made from post consumer recycled plastic it will be necessary to confirm that the recycling process used was suitable and authorised. (not sure of the rules in Ukraine)

Raw materials which are permitted in one country may not be legal in another so you need to know where the product will be sold as well.

Listing out the components of the product will help you to understand what hazards may occur during processing and use. 

Wow! That's a lot of investigation, eh? We've never done that, luckily we're FSSC certified, not BRC:)

Dear Sir and Madam. We have some doubts how to make description according to a clause 2.2.3: exempt: “origin of raw materials, including use of recycled materials”. How should it be? Should it include origin country of each of the components or type of product (organic, mineral etc.), type of manufacture process? etc? For example: we may try out to describe a laminated polymer film with some printing. This product includes a lot of components: a film, an ink, a lacquer, an adhesive, some additives, retention solvent in layer. We’re looking forward to your advices. Thanks for advance Have a nice day

IMO, two things are enough:

- name of the last processor of received material

- ensuring that they have a effective traceability system. (e.g. by auditing)

So what does the Guidance suggest ?

I doubt it, I think it means YOUR use of recycled materials

Do you mean we only have to indicate which materials are recycled and which is a new one?

Wow! That's a lot of investigation, eh? We've never done that, luckily we're FSSC certified, not BRC:)

2.2.3 - A full description of the product, product group and process shall be developed, which
includes all relevant information on product safety and integrity. As a guide this shall
include:
 • composition (e.g. raw materials, inks, varnishes, coatings and other print chemicals)
 • origin of raw materials, including use of recycled materials
 • intended use of the packaging materials and defined restrictions on use; for example,
direct contact with food or other hygiene-sensitive products, or the physical or chemical
conditions.

 

Hi Olena,

afaik FSSC22000 (sensibly IMO) limits itself to Safety. Nonetheless ............

Re  -2.2.3 - More concisely - What is the safety/integrity risk associated with the raw materials in the context of their intended final usage ?

Except for integrity, sort of standard HACCP/PRP.

IMEX for food customers, they require (packaging) supplier's evidentiary documentation that plastic packaging does not contain recycled plastic.

The BRC does tend towards a Quality and Legality Standard as well, probably because it was originally developed by retailers and they want their backsides covered from every direction.

Contrary to Charles comments I am finding that retailers and food customers are requiring more and more use of recycled content in packaging which I ( perhaps cynically but perhaps not) believe is so that they can claim the environmental kudos whilst pushing the technical problems onto the packaging manufacturers.

Agree Foodworker,  we're certainly seeing a strong push on the sustainability front from our customers. Which is requiring a reduction in plastic, an increase in recycled content along with the ability to recycle the end packaging. Our packing suppliers are already on the way to meeting these objectives - they've seen the writing on the wall.

Agree Foodworker,  we're certainly seeing a strong push on the sustainability front from our customers. Which is requiring a reduction in plastic, an increase in recycled content along with the ability to recycle the end packaging. Our packing suppliers are already on the way to meeting these objectives - they've seen the writing on the wall.

Re - my recycling comment - perhaps I should have added (a) the word "some" before food, (b) requirement was "Destination" (not UK) sensitive.

Regardless, several other receivers have required equivalent testing documentation.

Hi Vasiliy,

We recently had the audit and the auditor accepted our Statement of Compliance and some risk assessment as the documentation required in clause 2.2.3.

The first point, composition, seems to refer to the final product. In our SoC there is a wide description of the product we manufacture and all the components included in it.

The second point was included in a risk assessment, where the raw materials come from and whether they have any certification (in our case FSC). Although now I notice we are missing the recycled cardboard, but I assume we would be covered by having the SoC/DoC/SPECs from the supplier.

The intended use is also included in our SoC.

With this we got it covered, audited and it performed quite well! 

I hope it helps  

The conclusion IMO is that auditors are also uncertain as to level of detail required in the specific case and, perhaps, specific location.

@ Halo - Thks yr input.

Returning to the specific OP, did yr "details" happen to include any "recycled" items ?

If so, how did you respond to the request for "origin" ?