BRCGS Standard for Packaging Materials Issue 6

P614 – Guidance Document

Disposable food contact packaging/consumer items

Document Scope:
The aim of this document is to provide guidelines on the most appropriate Standard
to be used for the certification of manufacturing facilities producing disposable food
contact packaging items.

Change Log

Version Issue Date Details

0.1 09/06/2020 Draft Issue 6 for review by BRCGS

0.2 16/06/2020 Updated table with additional products

0.3 09/07/2020 Updated following consultation with Packaging TAC

1 15/07/2020 Published first version guidance document

1.1 16/07/2020 Small formatting change

P614 Position Statement - disposable food contact

BRCGS Packaging Materials, Issue 6
packaging/consumer items
Version 1.1: 16/07/2020 Page 1 of 5
Background
A few packaging manufacturing sites who also produced disposable plastic and
paper items for use in the food service sector were certificated to issue 5 of the
BRCGS Packaging and Packaging Materials Standard. The same products are also
manufactured by sites certificated to the BRCGS Consumer Products Standard.
Therefore, in terms of functionality, these products sit on the borderline between
packaging materials and consumer products

The purpose of this document is to provide sites and Certification Bodies guidance
on which Standard provides the greatest consumer protection with regards to the
manufacture of this range of products and where the choice of Standard is optional.

The BRCGS Packaging Materials Standard Issue 6 is primarily intended to cover sites
manufacturing packaging materials or the raw materials used to manufacture
packaging materials. It is a GFSI benchmarked Standard.

It covers areas common to all BRCGS Standards e.g. Senior Management

Commitment, Hazard and Risk Management, documented Quality Management
systems, Good Manufacturing Practices and Personnel. There is a specific emphasis
on the management of product quality, product development, functionality, and
print control.

The Consumer Products Standard is intended for manufacturing sites producing non-
food raw materials, components and finished products destined for purchase by the
end consumers for personal use. There is no GFSI Benchmark available for non-food
Consumer Products for any scheme.

Whilst this Standard also covers the areas common to all BRCGS Standards, it has a
specific emphasis on finished product legality, claims substantiation and consumer
safety in use (Product risk management), design, contamination control and product
inspection and testing. The Standard is divided into Personal Care and Household
which caters for single use/food contact/hygiene sensitive products and General
Merchandise. The Standard has two levels of certification, Foundation and Higher
level where, subject to scope of the site operations, the Higher level is more
applicable to most of the products covered by this document.

Objectives

It is recognised that there are some sites that manufacture both packaging materials
and consumer products where the manufacturing material or technologies are the
same. The objective of this document is to enable where applicable

• Compliance with specific customer requirements e.g. for GFSI recognised

certification
• Reduction in audit and certification costs for sites by certification to a single,
rather than multiple Standards.

P614 Position Statement - disposable food contact packaging

BRCGS Packaging Materials, Issue 6
/consumer items
Version 1.1: 16/07/2020 Page 5 of 5
 • Certification to a Standard which provides a valid assurance of consumer
protection and legality
• Accreditation of the certification process
• Appropriate auditor competence criteria to undertake the assessment
process effectively.

Product / Standard selection table

The table below shows common product groups and the primary Standard i.e. the
Standard which is most suitable for the product type. The options summarise the
conditions under which an alternative Standard may be used with appropriate
justification. The site/factory is certificated dependent on the main focus of sites current
operations. The list provided is not exhaustive.

Note: Where a Standard other than the primary Standard is used it shall be
recognised that the certificate may not be accredited dependent on the
Certification Body and Accreditation Body and this should be checked with the
Certification Body.

Product/Product Group Primary Options

Standard

Cups & Lids

Single use plastic/paper cups and lids Either Packaging Materials Standard is acceptable
Packaging where the purpose of the final product is for use in
Materials or the food service sector and/or where the factory
Consumer is predominantly producing packaging materials
Products PCH* (at least 70%)
Consumer products Standard is acceptable
where the final product is purchased largely for
domestic use by a consumer.

Re-useable plastic, glass, metal, Consumer General Merchandise Higher level. These items
ceramic cups Products are washed before use.

Straws

Single use plastic/paper drinking Either Packaging Materials Standard is acceptable

straws Packaging where the purpose of the final product is for use in
Materials or the food service sector and/or where the factory
Consumer is predominantly producing packaging materials
Products PCH* (at least 70%).
Consumer products Standard is acceptable
where the final product is purchased largely for
domestic use by a consumer.

P614 Position Statement - disposable food contact packaging

BRCGS Packaging Materials, Issue 6
/consumer items
Version 1.1: 16/07/2020 Page 5 of 5
Re-useable metal/plastic straws Consumer General Merchandise Higher level. These items
Products are washed before use.

Napkins

Single use Paper Napkins Either Packaging Materials Standard is acceptable

Packaging where the purpose of the final product is for use in
Materials or the food service sector and/or where the factory
Consumer is predominantly producing packaging materials
Products PCH* (at least 70%).
Consumer products Standard is acceptable
where the final product is purchased largely for
domestic use by a consumer.

Bags, Storage containers

Single Use plastic, paper, metal food Either Packaging Materials Standard is acceptable
bags, containers, and lids Packaging where the purpose of the final product is for use in
Materials or the food service sector and/or where the factory
Consumer is predominantly producing packaging materials
Products PCH* (at least 70%).
Consumer products Standard is acceptable
where the final product is purchased largely for
domestic use by a consumer.

Bin/trash bags Either Packaging Materials Standard is acceptable

Packaging where the purpose of the final product is for use in
Materials or the food service sector and/or where the factory
Consumer is predominantly producing packaging materials
Products PCH* (at least 70%).
Consumer products Standard is acceptable
where the final product is purchased largely for
domestic use by a consumer.

Re-useable plastic, ceramic, glass, Consumer General Merchandise Higher level. These items
metal containers and lids Products are washed before use.

Plates

Single use plastic/paper plates Either Packaging Materials Standard is acceptable

Packaging where the purpose of the final product is for use in
Materials or the food service sector and/or where the factory
Consumer is predominantly producing packaging materials
Products PCH* (at least 70%).
Consumer products Standard is acceptable
where the final product is purchased largely for
domestic use by a consumer.

Re-useable plastic, ceramic, metal Consumer General Merchandise Higher level. These items
plates Products are washed before use.

Tablecloths/Tray Liners

P614 Position Statement - disposable food contact packaging

BRCGS Packaging Materials, Issue 6
/consumer items
Version 1.1: 16/07/2020 Page 5 of 5
Paper/plastic Tablecloths/tray liners Either Packaging Materials Standard is acceptable
Packaging where the purpose of the final product is for use in
Materials or the food service sector and/or where the factory
Consumer is predominantly producing packaging materials
Products* (at least 70%).
Consumer products Standard is acceptable
where the final product is purchased largely for
domestic use by a consumer.

Textile tablecloths Consumer General Merchandise

Products

Utensils, cutlery

Single use Either Packaging Materials Standard is acceptable

Packaging where the purpose of the final product is for use in
Plastic/wooden/bamboo cutlery
Materials or the food service sector and/or where the factory
Consumer is predominantly producing packaging materials
Products* (at least 70%).
Consumer products Standard is acceptable
where the final product is purchased largely for
domestic use by a consumer.

Re-useable Plastic/wooden/bamboo Consumer General Merchandise Higher level. These items

metal utensils, cutlery Products are washed before use.

Personal Protective Equipment, PPE

Grill gloves Consumer General Merchandise

Products

Thermometers Consumer General Merchandise

Products

Hand sanitisers Consumer

Products PCH*

Single use Personal protective Consumer

equipment gloves, hair coverings and Products PCH*
face masks

* Consumer Products issue 4 Personal Care and Household

P614 Position Statement - disposable food contact packaging

BRCGS Packaging Materials, Issue 6
/consumer items
Version 1.1: 16/07/2020 Page 5 of 5