10 Aug 2026

BRCGS Packaging Materials: what are the main challenges for packaging manufacturers?

BRCGS Packaging Materials: what are the main challenges for packaging manufacturers?

Manufacturing packaging involves much more than meeting technical specifications. The origin and composition of materials, manufacturing and storage conditions, traceability, and the ability to prevent contamination can all affect product safety and, ultimately, customers and end consumers.

BRCGS Packaging Materials provides a framework for managing these risks and manufacturing packaging materials that are safe, legal and meet specified quality requirements. With more than 6,800 certified sites across over 90 countries, certification is particularly relevant to companies supplying the food industry and other sectors with demanding safety and quality requirements.

Experience from audits conducted against Issue 7, effective since April 2025, is already highlighting some of the main challenges in applying the Standard and the areas where companies can improve.

 

What are audits showing?

PBRCGS Packaging Materials currently has more than 6,800 certified sites across over 90 countries. Since audits against Issue 7 began in April 2025, approximately 38,000 major and minor non-conformities have been recorded. This provides valuable insight into the trends and areas that continue to require attention from packaging manufacturers.

At a global level, major non-conformities have included issues related to senior management commitment, product safety and quality management systems, process control and site standards. Other recurring audit findings include traceability, sharp and metal control, housekeeping and hygiene, maintenance, pest management, vulnerability assessment, flow diagram verification, and hazard analysis and risk assessment.

These findings show that effective certification relies both on manufacturing conditions and on the consistency of the management systems behind them. Understanding the areas that most frequently lead to non-conformities can help companies focus internal audits, training and improvement activities where they can have the greatest impact.

 

Hazard analysis is only as good as your understanding of the process

Hazard analysis is one of the key areas requiring attention.

Identifying the most obvious risks is not enough. Organisations need to consider all reasonably foreseeable hazards associated with raw materials, processes, people and the intended or foreseeable use of the packaging.

Cross-contamination, allergens, tampering and critical packaging defects are among the issues that can be overlooked. Foreseeable uses other than those originally intended should also be considered. Packaging designed for cold use, for example, could potentially be used by a consumer to heat food.

Process flow diagrams are therefore an important part of the analysis. Activities such as artwork approval, returns, the reincorporation of materials or the return to production of samples used for testing may need to be included.

The most effective way of checking that nothing has been overlooked is to verify the flow diagram on site, following materials and products through the process and confirming that the document accurately reflects what actually happens.

 

Vulnerability is not just a food issue

Vulnerability assessment is another area that deserves attention, particularly for companies sourcing raw materials through complex supply chains or using recycled materials.

In the packaging sector, the assessment should consider the characteristics of the materials themselves and situations where there may be an economic incentive for fraud or substitution.

Recycled content, material composition, the number of layers and specific barrier properties are some examples.

Understanding the origin of raw materials and properly assessing suppliers is therefore essential. BRCGS Packaging Materials Issue 7 provides different mechanisms for supplier approval, allowing the level of control to be adapted to the associated risk.

 

Having traceability is not the same as proving that it works

Traceability continues to feature among non-conformities identified internationally.

This does not necessarily mean that a company has lost track of a product. In some cases, the weakness lies in how the traceability system is tested and how its effectiveness is demonstrated.

An organisation working with different product groups should ensure that its exercises are sufficiently representative. The exercise does not end when the relevant documentation has been gathered: the results must be assessed and a conclusion reached as to whether the system performed as intended.

During an audit, the organisation should be able to demonstrate effective traceability, with four hours being the indicated reference for completing the exercise.

When an incident occurs, this preparation can make a significant difference to how quickly raw materials, batches, suppliers and potentially affected customers can be identified.

 

The problem has been corrected. But could it happen again?

This is one of the most important questions following a non-conformity.

Consider an operator who uses the wrong material. The immediate conclusion may be simple: human error. The response may seem equally straightforward: retrain the employee.

A closer investigation may reveal something different. Containers may not have been labelled; labels may have been removed during cleaning and not replaced; there may have been no subsequent verification; or the risk may never have been considered in the first place.

In that situation, retraining the operator does not remove the cause of the problem.

Tools such as the 5 Whys and the Ishikawa Diagram can help teams investigate underlying causes and establish actions that genuinely reduce the likelihood of recurrence.

At the next audit, the organisation will not only be assessed on whether the previous issue was corrected. The effectiveness of the actions taken and the existence of similar situations elsewhere in the organisation will also be considered.

 

Certification works when it becomes part of everyday operations

Strong results do not necessarily depend on having more documentation. They depend on understanding risks, controlling processes and involving people.

The experience of certified companies illustrates this well. At Intraplás, a packaging manufacturer serving the food sector with a strong export focus, BRCGS Packaging Materials is integrated into day-to-day quality and food safety management.

Internal audits, training, awareness campaigns, food safety culture surveys and regular communication with employees are among the practices used to keep these issues visible throughout the year.

Senior management involvement is also important, but information should not flow in one direction only. Giving teams opportunities to report risks and difficulties and suggest improvements can help identify problems that procedures and audits alone may not reveal.

This integration allows certification to move beyond an exercise associated with the audit date and become part of how the business manages its processes.

 

Why become certified to BRCGS Packaging Materials?

For many packaging manufacturers, certification is already a requirement for accessing certain customers and supply chains.

Its value, however, goes beyond the certificate itself.

Consistent application of the Standard can strengthen the management of packaging-related risks, improve traceability, provide a structured approach to supplier assessment, reduce the likelihood of incidents and establish a common approach to safety and quality throughout the organisation.

In an industry where a packaging failure can have consequences throughout the supply chain, this capability also strengthens confidence among customers and business partners.

 

Ready to pursue BRCGS Packaging Materials certification?

 

APCER supports organisations throughout the BRCGS Packaging Materials certification process, with an approach tailored to each company's operations and needs. Talk to us!

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