BRCGS Packaging Issue 7: transition, top NCs and food contact risks

Packaging Issue 7 Q&A: environmental monitoring, culture plans, the most common NCs, HARA, confidential reporting and new packaging materials.

We deliver BRCGS Packaging Sites and Auditor training every month. These are the questions that come up most.

Q: Is the environmental monitoring requirement worth it?

Only if the value is designed in. Your risk assessment defines whether and what testing is needed, and you need corrective and preventive actions ready to implement when results come back. One course attendee described an NC where a site found Listeria and did nothing about it. That is testing for its own sake. In Packaging Issue 7 the need for environmental monitoring is decided by your own risk assessment.

Q: What are auditors looking for in the culture plan?

More than a poster. A live action plan that covers every bullet point of the clause, with meaningful SMART actions. It’s a topic that threads throughout the standards and is the foundation of every section, not only senior management commitment. For a practical way to involve everyone, see QTC's onsite Culture Fest.

Q: What are the most common Issue 7 non-conformities?

UK Food Certification (now Amtivo) published the top 10 from the first six months of Issue 7, in no particular order:

Site facilities and GMP - 4.1.3 Building fabric: maintenance creating hygiene risks - 4.8.1 Housekeeping: cleaning standards not maintained in some areas or machinery - 4.9.1.2 Glass and brittle plastic: outdated registers or incomplete checks - 4.9.3.1 Chemical control: unlabelled containers - 4.11.5 Pest proofing: open doors, missing netting

Records and systems - 2.4.1 HARA process flow: missing steps or inputs/outputs - 2.10.3 HARA review: not covering all clause requirements - 3.5.2 Internal audit plan: missing required elements - 4.6.3 New equipment commissioning: no formal procedure - 4.8.2 Cleaning procedures: missing risk assessments, incomplete records or unverified data

The top Issue 6 NCs in the BRCGS Annual Report 2024–25 were similar (housekeeping, temporary repairs, chemicals, pest control, walls and floors), so the same issues keep coming back. Beyond investment in buildings and training, the biggest lever is communication: staff need to know how and what to report, with regular reminders through pre-shift talks, refreshers and posters. BRCGS publishes NC data for each Standard in its annual report; Packaging's housekeeping clause 4.8 matches 4.11.1 in Food Safety Issue 9. We cover the common non-conformities on our BRCGS Packaging Sites Issue 7 training.

Q: Do we have to use an external party for confidential reporting?

No. Reports must be able to be made anonymously and kept confidential, and the auditor needs to see a system to handle them. Any site can use our free STC confidential reporting tool. Confidential reporting is required across the BRCGS Standards, not only Packaging.

Q: How do we assess food safety risks from new packaging (compostable, recycled, multi-layer)?

• All plastics carry some risk of leachables and extractables; softer plastics are typically higher risk. Heat matters most if storage conditions are abused or the product is heated or cooked in the pack.
• Get the food contact declaration of conformity referencing the applicable legislation (for example Regulation (EU) No 10/2011 on plastics, as amended), and the specification showing the limits of use.
• Read the specification and use the packaging within its limits. Auditors often find specs filed but not read, and packaging used beyond its conditions, which invalidates the assurances.
• Recycled content isn't automatically less safe: recycling processes are usually aggressive (washing, heat) and should be validated by the supplier.
• Document the risks and assurances in your HACCP/HARA and raw material/packaging risk assessments, and consider the full shelf life, including any extension such as freezing.

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Reviewed by Cathy Gladwin, Director & BRCGS ATP Trainer, STC · November 2026

These Q&As share general best practice from our trainers and auditors. They aren't consultancy advice for your site. For support specific to your site and systems, we can refer you to our sister company QTC.

Learn more: BRCGS Packaging Issue 7 Sites, Packaging Auditor, HARA and Environmental Monitoring. See the course calendar.