BRCGS Packaging Materials Issue 7 – what has changed since April 2025?

From 28 April 2025, all audits of packaging materials manufacturers must be conducted in accordance with the new, seventh edition of the BRCGS Packaging Materials standard. For companies holding Issue 6 certification, this means they must adapt their management system to the updated requirements. Below we outline the most significant changes that Issue 7 introduces in practice.

Key substantive changes

A key change in Issue 7 is a thorough overhaul of the requirements concerning hazard analysis and risk assessment – in the standard’s terminology, this is referred to as HARA (Hazard Analysis and Risk Assessment). The new edition aligns HARA with the principles of the Codex Alimentarius, bringing its structure closer to the HACCP system used in food standards. The requirements have been made more detailed: the analysis must cover not only physical, chemical and biological hazards, but also operational risks (e.g. equipment failures, human error) and hazards arising from the migration of chemicals from packaging material into the product.

Issue 7 also introduces formal requirements regarding product safety culture – analogous to what Issue 9 of the Food Safety standard introduced for food producers. The facility must demonstrate that product safety measures are embedded in the organisation’s daily practice, and not merely recorded in documents.

The scope of certification has also been expanded: Issue 7 now covers manufacturers of biodegradable and compostable packaging, digitally printed materials and single-use products (cups, plates, cutlery, straws). This is a significant change for companies operating in the eco-friendly and catering packaging sectors, which until now have operated in a classification grey area.

Changes to the audit protocol

Issue 7 also modifies the rules for conducting audits. Alongside the existing announced audit, a blended announced audit option has been introduced – part of the assessment may be carried out remotely using ICT tools, which gives sites greater logistical flexibility whilst maintaining the full credibility of the certification.

The requirement for a mandatory unannounced audit every three years has been retained. For facilities applying for higher levels of certification, the unannounced audit remains a mandatory element and is the aspect most highly valued by customers in the supply chain.

More detailed requirements regarding traceability have also been introduced: the facility must be able to trace the path of raw materials to the finished product and vice versa within a maximum of four hours, including outsourced processes.

Issue 6 and Issue 7 – what actually needs to be changed?

Issue 7 is an evolution, not a revolution. Companies that are already implementing the system effectively under Issue 6 do not face the need to overhaul the entire system – but several areas require specific action:

• HARA – review and update the existing hazard analysis in line with the new structure; supplement it with operational risk and the migration of chemical substances
• Product safety culture – development of a documented action plan with measurable indicators, if the site did not previously have one
• Scope of certification – verification that the product groups manufactured (e.g. biodegradable packaging, single-use products) fall within the current scope of the certificate
• Traceability – checking whether traceability procedures meet the 4-hour requirement, including for outsourced processes
• Audit protocol – familiarising oneself with new audit options and, where necessary, adjusting the planning of internal audits

Issue 7 is an evolution, not a revolution – but it requires specific actions to be taken before the next audit. If you need support in adapting your system, we implement BRCGS with a guarantee of certification.