BRCGS Packaging or FSSC 22000: What the Auditor Checks on Your Floor (and What Drives the Cost)
As of 17 Oct 2026, a packaging plant is audited against BRCGS Packaging Materials Issue 7 (live since 28 Apr 2025) or FSSC 22000, Version 6 until 30 Apr 2027 and Version 7.0 from 1 May 2027. On the floor, both cover seven areas: zoning, glass, sharps, pests, foreign bodies, traceability, training. Cost follows auditor-days, set by full-time-equivalent (FTE) count.
Last checked: 17 Oct 2026
By the Mama Editorial Team, for owners of Indian converters asked for a GFSI-recognised certificate. Published standard texts only. It is not legal or certification advice; the certification body (CB) you contract decides what conforms.
Key takeaways
- BRCGS Packaging Materials Issue 7 was published on 28 Oct 2024, and BRCGS made it the only issue audited from 28 Apr 2025, according to LRQA's summary of the BRCGS launch and the date on BRCGS's own Issue 7 audit checklist.
- FSSC 22000 Version 7.0 was published in May 2026. V6 audits are allowed only until 30 Apr 2027, and upgrade audits to V7 run from 1 May 2027 to 30 Apr 2028, per the FSSC V7 Upgrade Process, 1 May 2026.
- Packaging falls in FSSC food chain category I, audited against ISO 22000:2018, ISO 22002-100:2025, ISO 22002-4:2025 and the FSSC additional requirements (FSSC V7, Part 1, Table 1).
- BRCGS Issue 7 marks eight areas "Fundamental", including traceability (3.10), housekeeping and cleaning (4.8) and training (6.1), per the P701a checklist (checked 17 Oct 2026).
- FSSC requires at least half of the audit time to be spent on operational planning and PRPs, "including time spent auditing the facilities", and an unannounced audit at least once every three years (FSSC V7, Part 3, 4.3 f and 5.4.1).
Verified against
- BRCGS, Global Standard Packaging Materials Issue 7 — Audit Checklist and Site Self-Assessment Tool, P701a, English, v1, 28 Oct 2024 (DOCX on brcgs.com), which reproduces every clause of the standard
- BRCGS, Packaging Materials Standard — Guide to Certification and Celebrating 25 years of Packaging Materials, 9 Oct 2026
- Foundation FSSC, FSSC 22000 Scheme Version 7.0, May 2026, Parts 1–3
- Foundation FSSC, Version 7 Upgrade Process, 1 May 2026
- ISO 22000:2018 and ISO 22002-4:2025 are sold by ISO and were not read; their clause numbers below are the ones the FSSC scheme cites.
- Checked 17 Oct 2026.
What the auditor looks at, area by area
The table maps each floor area to both standards' clauses and the evidence that usually answers them. FSSC clause numbers are from V7, which applies to audits from 1 May 2027; until then CBs audit V6 (checked 17 Oct 2026).
| Floor area | BRCGS Packaging Issue 7 clause | FSSC 22000 V7 clause | What the text asks the auditor to see | Typical evidence on the day |
|---|---|---|---|---|
| Hygiene zoning and layout | 4.5.1–4.5.6; 4.4.1 | ISO 22002-4:2025 (PRPs, cat. I); 2.5.12 site inspections | A current site plan showing personnel access points, routes for materials, waste and people, and "areas requiring additional control such as 'clean rooms'" (4.5.1); outer-packing removal in "a designated, segregated area" (4.5.5) | Dated site plan; marked walkways; de-boxing area apart from the line |
| Glass and brittle materials | 4.9.1.1–4.9.1.3 | 2.5.11 d) iii breakage procedure | A register with "location, number, type and condition" and recorded checks "at a specified frequency" (4.9.1.2); a named person in charge of each breakage clean-up; "All breakages shall be recorded in an incident report" (4.9.1.3) | Glass register; check sheets; breakage reports; protected tube lights, including on fly-killers (4.2.6) |
| Sharps and metal | 4.9.2.1–4.9.2.2 | 2.5.11 d) i–iii | Controlled issue of knives, blades, needles and wires, with a "record of replacement or breakage"; "Snap-off blade knives shall not be used" (4.9.2.1) | Knife issue log; blade-exchange record; no snap-off cutters at the slitter or bag-making machine |
| Pest control | 4.11.1–4.11.9 | ISO 22002-4:2025 (PRPs) | A preventive programme for "all areas of the site"; inspection frequency set by risk assessment (4.11.2); a signed site plan of "numbered pest control devices" (4.11.8); catch analysis from fly-killers "at appropriate intervals" (4.11.7) | Pest contractor contract; numbered bait-station map that matches the walls; trend reports |
| Foreign bodies and contamination | 4.9.5.1–4.9.5.5; 4.8 (Fundamental) | 2.5.11 d) i–iii | No staples, paper clips or drawing pins in open product areas (4.9.5.3); sealed wooden furniture (4.9.5.2); site-issued phones and tablets controlled (4.9.5.4); cleaning schedules that name who, what, how often and how verified (4.8.2) | Cleaning records; walk past the line for loose items; FSSC: a risk assessment for "magnets, metal detectors, X-ray equipment, filters, and sieves", or a written justification for none |
| Traceability | 3.10.1–3.10.6 (Fundamental) | ISO 22000:2018 8.3; 2.5.2 c) where a claim is made | A test across product groups, raw material to customer and back, "at a minimum annually", that "should be achievable within 4 hours" unless law or customer says otherwise (3.10.4); traceability kept through rework and recycling (3.10.5) | A live trace on the day: the auditor picks a reel or a lot and watches the documents come out |
| Print and artwork | 5.2–5.3 | 2.5.2 d) i–vi | Approved master sample; approval of each print run; detection of print errors during the run; segregation of print variants; accounting for unused printed product (FSSC 2.5.2 d) | Signed first-off; master-sample file; reconciliation of printed waste |
| Personal hygiene | 6.2.1–6.2.6 | ISO 22002-100:2025 (PRPs) | Rules on watches, jewellery, nails and perfume, "checked routinely" (6.2.1); phones in production "controlled and managed" (6.2.2); plasters of a colour different from the product, "preferably blue" (6.2.4) | Hygiene rules at the entry; routine check sheets; plaster stock |
| Training records | 6.1.1–6.1.6 (Fundamental) | 2.5.6 f) allergens; 2.5.8 culture | Temporary personnel and contractors trained "prior to commencing work"; training "in the appropriate language of trainees" (6.1.2); records with trainee name, date and duration, contents and provider (6.1.5) | Induction register for contract and seasonal workers; Hindi or regional-language material; competency sign-offs for operators at control points (6.1.3) |
The eight "Fundamental" clauses in BRCGS Issue 7
BRCGS flags some clauses as "Fundamental"; the P701a checklist marks eight: 1.1 senior management commitment, 2.0 hazard analysis and risk assessment (HARA), 3.4 specifications, 3.5 internal audits, 3.10 traceability, 4.8 housekeeping and cleaning, 5.4 manufacturing process control and 6.1 training and competence (checked 17 Oct 2026).
Three of the eight are decided largely on the floor: housekeeping (4.8), process control (5.4) and the trained, supervised operator (6.1). The converter's own changeover and waste losses, which sit next to 5.4, are on the packaging and printing plant page.
BRCGS's 9 Oct 2026 update says critical non-conformities in the second year of Issue 7 audits were raised in areas "that includes HARA implementation and the use and effectiveness of internal audits".
What is new for a packaging plant in FSSC V7
FSSC V7 clause 2.5.1 e) asks category I sites to set criteria for "the use of recycled packaging as a raw material input" and to meet legal and customer requirements on it (May 2026).
Clause 2.5.12 asks category I sites for "routine (e.g., monthly) site inspections/PRP checks" of the site, production environment and equipment, with frequency and content "based on risk" (May 2026).
Clause 2.5.9 c) asks for line start-up and change-over procedures that ensure "labelling and packaging from the previous run have been removed from the line" (May 2026). For a printer, this is job-change line clearance.
How the day runs on the floor
The BRCGS Guide to Certification says the on-site audit assesses "the practical implementation" through "observation of procedures and processes, review of documentation, and staff interviews" (checked 17 Oct 2026).
FSSC V7 Part 3, 4.3 f) says at least 50% of the audit duration goes on operational food safety planning and PRPs, "including time spent auditing the facilities, conducting the traceability exercise(s) and reviewing the relevant records" (May 2026).
For an FSSC unannounced audit, "the site shall not be notified in advance", and the audit starts with an inspection of production facilities "commencing within 1 hour after the auditor has arrived on site" (FSSC V7, Part 3, 5.4.2).
The unannounced audit takes place in "normal operational working hours with consideration of all shifts" (FSSC V7, 5.4.2).
What happens after a finding
FSSC V7 has three grades of nonconformity, minor, major and critical, and "does not allow 'Opportunities for Improvement'" (Part 3, 6.2, May 2026).
A major nonconformity has to be closed by the CB "within 28 calendar days from the last day of the audit", or the certificate is suspended (FSSC V7, 6.2.2).
A critical nonconformity leads to suspension "within 3 working days" and a separate full on-site audit between six weeks and six months later; at an initial audit, a critical means "the audit is failed" (FSSC V7, 6.2.3).
For BRCGS, the Guide to Certification says non-conformities "will be closed out within 28 days following the audit" and the certificate is issued "within 42 calendar days from the first day of your audit" (checked 17 Oct 2026).
What sets the cost: auditor-days
A public fee table was not found in the BRCGS Guide to Certification, the Issue 7 checklist or the FSSC V7 scheme (checked 17 Oct 2026). The CB quotes the fee; the scheme fixes the minimum auditor time behind it.
FSSC V7, Part 3, 4.3.1 sets the site audit time as Ds + TFSSC: Ds comes from ISO 22003-1:2022, and TFSSC is added on top by headcount (May 2026).
The table shows the FSSC floor: the minimum audit time plus the minimum preparation and reporting time. Real Ds from ISO 22003-1 is usually higher, so treat these as the least auditor time a CB can plan, not the likely figure.
| Full-time equivalents (FTE), max 2 HACCP studies | TFSSC added (auditor-days) | Minimum audit duration, any audit type (days) | Minimum preparation (days) | Minimum reporting (days) | Minimum auditor-days (audit + preparation + reporting) |
|---|---|---|---|---|---|
| Under 100 | 0.5 | 1.5 | 0.25 | 0.5 | 2.25 |
| 100–249 | 1.0 | 2.0 | 0.25 | 1.0 | 3.25 |
| 250 or more (or 3+ HACCP studies) | 1.5 | 2.5 | 0.25 | 1.0 | 3.75 |
Source: FSSC V7, Part 3, 4.3.1.1, 4.3.1.2 and 4.3.3 (minimum Ds is 1 day; reporting can drop to 0.5 day only where the audit itself was 1.5 days), May 2026.
A plant of 250 FTE or more sits in the bottom row; one of 200–249 FTE sits in the middle row. Surveillance audits are calculated as one-third of Ds plus TFSSC, and recertification as two-thirds of Ds plus TFSSC (FSSC V7, 4.3.2), but the minimum duration in the table applies to every audit type.
An interpreter adds "at least 20%" to the audit duration for the part of the audit where one is needed (FSSC V7, 4.3.1).
The certificate is valid for at most three years from initial certification, with subsequent three-year cycles and surveillance audits in between (FSSC V7, Part 3, 7.1).
What cameras do not answer
Neither standard names CCTV, and the camera questions buyers raise are covered on the buyer audits and CCTV page. This page is about the floor itself.
Footage cannot show that a glass register is complete, that a bait station is numbered, or that an operator understood the induction. Those clauses are answered by records and by what the auditor sees on the day.
Footage can help with clauses where the question is "did it happen": that the line was cleared before the next job (FSSC 2.5.9 c), that a breakage was cleaned up and the area isolated (BRCGS 4.9.1.3), or what left the dock in a short-shipment claim, the subject of the packing and dispatch CCTV specification.
Who decides
The CB decides whether your site conforms, and the certification decision is the CB's (FSSC V7, Part 3; BRCGS Guide to Certification). The brand owner decides which certificate it accepts and whether its own supplier manual adds anything; ask for that in writing.
BRCGS position statements "are binding and are considered to be an extension of the standard", per the BRCGS Packaging Materials page (checked 17 Oct 2026). FSSC's Board of Stakeholders decision list can also "overrule or provide further clarification on existing Scheme rules" (FSSC V7, Part 2, 2.2). Check both before the audit.
Where Mama fits
Mama reads the cameras a plant already has and sends the owner a short note each morning about machines and lines: which ran, which stood idle, and how long changeovers took. It watches machines and flows, not named people, and it does not produce audit evidence or replace the registers above. Leave an email or phone in the form below.
FAQ
Is BRCGS Packaging Issue 6 still audited?
No. BRCGS made Issue 7 the audited issue from 28 Apr 2025, per LRQA's summary of the BRCGS launch; Issue 7 was published on 28 Oct 2024 (checked 17 Oct 2026).
Which ISO prerequisite standard applies to a packaging plant under FSSC 22000?
FSSC V7 Part 1, Table 1 lists ISO 22000:2018, ISO 22002-100:2025 and ISO 22002-4:2025 plus the FSSC additional requirements for category I, "production of packaging material in contact with food, feed, and animal food" (May 2026).
How fast should a traceability test be?
BRCGS Issue 7 clause 3.10.4 says traceability "should be achievable within 4 hours unless otherwise specified by local legislation or customer requirements", and the test runs at least annually across product groups (checked 17 Oct 2026).
Can the FSSC auditor turn up without notice?
Yes, after initial certification. FSSC V7 requires at least one unannounced surveillance audit in each three-year period; the initial stage 1 and stage 2 audits "cannot be performed unannounced", and blackout days are agreed in advance (Part 3, 5.4).