Hello, and welcome to our presentation on BRCGS Packaging Materials, Issue 6: The Learnings from the First 12 Months of this Standard Going Live. My name is Emma Hosking, and I am the Global Product Manager for SGS, and my colleague, Dorota Zulawnik, is our Non-Food Compliance Manager. We will be presenting this subject to you with some time at the end for any Q&A. We will be taking you through areas highlighting what has been performed well over the last 12 months, areas that sites have implemented successfully, but we will also be providing an insight to the areas where more attention is required in order to comply successfully with the standard. I hope you enjoy our presentation.
Just SGS at a glance: a certification body. We're the number one world leader, over 89,000 employees, just under 3,000 offices and laboratories, 11 global industries, and we offer local expertise globally. We offer solutions along the value chain, again, not lasting too long on this slide, but covering primary production, transport, logistics, and trade, processes, manufacturers, suppliers, retail, and food service, through all forms of testing, verification, and auditing training programs. Just a brief introduction, as I'm sure most of you on this call will be familiar with the standard. It's just aligning to the benchmarking requirements of the GFSI. The Global Standards for Packaging Materials, Issue 6, was published in August 2019, with the first day of audits taking place to this standard the 1st of February 2020. Just going to discuss very, very briefly some of the new issue changes.
Again, just a few of the issues where attention is sort of highlighted. One key area that aligns with the GFSI benchmarking is the development of a product safety culture. This is to drive and promote quality culture within a business in a sort of a positive direction. Another area that has been given focus is reducing the risk of exposure to fraud. There is a key emphasis on continuing improvement within this new issue, and this is by emphasizing effective root cause analysis and a robust internal audit program. There is a new section, the Microbiological Environmental Monitoring Program, which is being introduced and is based on risk. It touches on product authenticity, claims, and chain of custody. Another element is the inclusion of traded goods into the core standard.
Touching back to the product safety culture, SGS has created a product safety culture assessment, Realize, which has been customized specifically toward the industry. This new SGS Realize program has been specifically designed to address the culture requirements by providing an effective means of measuring culture and actionable intelligence that can be used to implement improvements. Should anyone be interested in this, please contact your local SGS office. So, just a couple more slides before I hand you over to Dorota. So, just as a brief sort of introduction and oversight to the data that Dorota will be presenting, SGS has issued over 800 packaging material certificates against the Issue 6 standard in a 12-month period. So, this is the data that we've analyzed and, as I say, come up with some sort of trend analysis for you, and this is using all three main audit options.
So, we have the on-site audit, which is the full on-site visit, as it suggests. We have the remote audit, which is, again, as it suggests, 100% remote and is a COVID-19 solution. Or we have the relatively new, the blended audit, which is up to 50% remote and a minimum of 50% on-site. So, just very quickly before I hand over to Dorota, we just have a very simple poll question, which if you could just take a couple of seconds to answer, that would be very much appreciated. The question being, "Are you currently certificated to the BRC Global Standards Packaging Materials, Issue 6 with SGS?" If you could simply select yes or no and then press submit, that would be great. So, without any further ado, I ,will now hand you over to Dorota. So, thank you very much, Dorota.
Thank you, Emma. I would like to share our observations from the audits we conducted during that year. This is the list of 20 clauses where non-conformities were raised during our audits, starting from the highest number. The vast majority concerns new or changed requirements, which, as it turned out, were not successfully implemented in the audited companies. As you can see, number one is product authenticity claims and chain of custody, which is a brand new clause. Then pest management, which was slightly changed. Next, hazard analysis and risk assessment with minor changes. Supplier approval and performance monitoring, this is one of the biggest changes in the new issue of the standard. Maintenance, especially temporary repairs and modifications, which hasn't changed, but this is always a clause causing problems. Housekeeping and cleaning, this is the rules how to keep good hygiene standard.
It also includes Microbiological Environmental Monitoring Program, which is new. Chemical and biological control, again with minor changes, however, always causes problems. Traceability requirements concerning this point extended significantly, covering supplier's traceability system, which is the most problematic. And so on. I will discuss the points in detail later in the presentation. And now a few words about what is being done well. New requirements have been introduced regarding control of documents and records that are in electronic form. At present, in most companies, documents are in electronic form, and it does not pose a problem as they are well maintained. When packaging for food or other hygiene-sensitive products is produced, a statement of compliance shall be maintained. Such a document, which in Europe is called the Declaration of Compliance, has been used for a long time, so it is not a novelty. It is not a problem.
Corrective and preventive actions, new fundamental clause. Again, it is not a novelty because it was required earlier, but not as a fundamental clause. Management of product withdrawals, incidents, and product recalls, implementation of the written guidance, and training for relevant staff regarding the type of event that would constitute an incident is required now. The requirement has only been extended with elements which should be included in the written guidance. The above-mentioned elements were implemented correctly, and we didn't register many non-conformities. Generally, the requirements regarding site standards haven't changed much. Several clauses have been added, which usually don't cause problems for the companies. However, the requirement, additional contamination control to elevated walkways, has often been omitted in implementation, and non-conformities with that particular clause happened.
We must remember that any places where elevated walkways exist, companies must provide effective methods to prevent contamination of the product due to people moving above production lines. Other new clauses in this point of the standard didn't cause such problems. Among them are site security and documented food defense plan, what is required now, a map or plan of the site with travel routes for personnel, raw materials, and intermediate and finished products, as well as routes for the removal of waste. Lubrication points and application methods of any lubricant must be clearly defined. It is a very important clause and requirement because, properly implemented, it can prevent contamination, which may be hard to detect. I must admit that this clause also still causes problems, although generally, evaluations are quite positive. As for maintenance, maintenance logs shall be maintained for all offline testing equipment.
In most companies, it was fulfilled before the requirements appeared, so it is not a big problem. As for housekeeping and cleaning, only the requirement was added that housekeeping and cleaning shall be based on risk, what is generally fulfilled. Although housekeeping and cleaning is not new, it always generates a large number of non-conformities during the audits. Areas and surfaces that are not clean enough are found too often to say that they do not cause product contamination risk. Additionally, 8.4.8 requires defining Microbiological Environmental Monitoring Program. This requirement generates very big problems, but I will talk about it when I discuss most commonly awarded non-conformities. As for waste and waste disposal, usually in most companies, external areas are cleaned and waste does not pose any problem. As for incoming goods, new requirements regarding this clause did not pose problems.
Procedure for inspection of loads on arrivals and procedure for the acceptance of raw materials were usually available, as well as the system to validate raw materials and intermediate products prior to their introduction to the process. The same as for storage of materials and intermediate and finished products, and again, the requirements regarding storage of materials and finished products did not pose problems. Procedures to maintain product safety and quality during storage based on risk were available. Companies most often have first in, first out (FIFO) system used for control of stock. In this case, the biggest problem was probably safe pallet storage when they were placed outside, so just as a reminder, pallets shall be properly protected if stored outside and inspected for signs of damage or contamination prior to use. Procedure for the dispatch and transport of products were well implemented.
Restrictions on the use of combined loads and requirements for the security of products during transit were identified, and preventive actions were usually implemented. Changes in the clause regarding training and competence did not pose problems either and were properly implemented. These changes concerned defining and documenting how new or changed procedures, working methods, or practices related to product safety or quality are communicated to relevant personnel. Communication is usually done in the form of trainings, and reviewing the effectiveness of training and trainers is required now and now, I would like to talk about the most common problems and non-conformities. A food safety and quality culture has been introduced following the food standards. These particular requirements came into force on the 1st of February, 2021, so the company should take steps to involve all employees to ensure product safety.
Starting from the sales department, for example, they must obtain from the customers the relevant information which allows them to design safe packaging, safe product. The information such as usage, what is to be packed, shelf life, filling, cupping, distribution, storage, and processing to which packaging can be exposed, such as processing in high temperature, heating, or cooling, and legal requirements in sales countries. All this information is necessary to select proper raw materials, including inks, glues, varnishes, and design safe packaging, which meet legal requirements, what is also very important. Design packaging is sent to the production department where it is made and where many hazards occur, which can make the packaging unsafe. This is why all employees must be aware of these hazards and work in a way which will eliminate them.
Therefore, it is vital to make the employees in all departments aware of the influence on the production of safe packaging and to engage them in obeying the work standards which allow to produce such safe packaging. This can be done step by step. First of all, you have to engage all employees and make them aware of the impact on the production of safe packaging. Then, identify strengths and weaknesses in your company, for example, based on the information from employees, but also from audits, both internal and external, hygiene inspections, some signals of non-keeping GMP rules, customer complaints, non-conforming products found during the production, etc. Based on the information, you should plan activities to implement the culture within time scales, implement the activities, and review the effectiveness of the activities.
But once again, the most important and crucial is to involve all employees to ensure product safety and make them aware of any safety hazards and to instruct them how to work to eliminate these hazards and consequently produce safe products. It is a requirement which came into force only two months ago, but it seems that it will cause many problems. Another new requirement which still causes problems, to my surprise, is the correct use of the proper logo. The most frequent non-conformity is the use of incorrect logo or the use of logo in a wrong way. So, just to remind you, the most important rules for using the logo are as follows. Companies that achieve certification and have no exclusion from the scope are qualified to use the BRCGS logo on marketing materials, for example.
The BRCGS logo may not be used by companies that do not include all produced products within the audit scope. The only exemption is exclusion of traded goods. In that case, the logo can be used. Generally, the logo shall not be used on products or product packaging. If the site is no longer certified because of certificate expiry, withdrawal, or suspension, the logo shall no longer be used. More information is available at the BRCGS website. It is very important that all certified companies become familiar with the requirements concerning the use of the logo. Some additional requirements have been added regarding the content of the management review, such as the effectiveness of the HACCP system and the effectiveness of the product defense and product fraud prevention plans, the impact of any applicable legislation and certification schemes changes, the evaluation of any objectives that have not been met.
The above-mentioned elements are often missing from the management review reports. I would like to draw your attention to additional documents published by BRCGS called position statements. They often include additional requirements. These documents can be found on the BRCGS website, so it is very important to check what is published on it. There were several such documents in the past, but now we have only one that includes all the ones published earlier. It is P618. It was published in March 2021, so it is very new. The document contains clarification of food defense and food fraud in the packaging materials standard, disposable food contact packaging versus consumer items, additional requirements for functional packaging claims, and allergen management control. Each certified company must get familiar with this document and implement its requirements. But please note that implementation dates are different for different requirements.
The last two came into force on the 1st of July 2021. The non-conformity that occurs very often is the lack of knowledge about these requirements and therefore no implementation. As for hazard and risk management, quality-related hazards have been excluded from 2.2 , and analysis of these hazards has been moved to clause 5.4, process control. However, the rules haven't changed. The whole analysis can be in one document, and therefore it does not cause problems. Two additional points, foreseeable misuse by consumer and potential for raw materials fraud, have been added and should be considered when identifying hazards, and these cause a lot of problems. In the new version of the standard, verification of compliance with the whole standard is required, as well as with any applicable modules. There is only one additional module available now, Plastic Pellet Loss Prevention.
Generally, the frequency of internal audits shall be based on risk associated with the activity and previous audit performance, but all processes shall be audited at least annually. The scope of the internal audit program must include higher-order product safety and quality plan, including the activities to implement it, prerequisite programs, product defense, and product fraud prevention plans, procedures implemented to achieve the standard and modules. The most frequent non-conformities concern the fact that not all processes are audited or there are objections to the frequency of the audit. In addition to internal audits, now a separate program of documented inspection is required, but only for sites manufacturing materials intended to be in contact with food or other hygiene-sensitive products. Inspections must focus on hygiene inspections mostly and shall be conducted as site visits. The frequency of these inspections shall be based on risk.
Most common solution is an inspection once a month, but the frequency may be different, for example, once in two or three months, but it must be justified by risk assessment. From our observations, it is evident that the companies do not always have a separate program for such inspections, and their frequency is often not based on risk. Supplier approval and performance monitoring is one of the biggest changes in the new issue of the standard. Currently, supplier approval methods should be based on risk and include either one or a combination of criteria. The first is valid certification to the applicable global standard or GFSI-recognized standard, and/or the second is supplier audit, and/or the last one is the supplier questionnaire, but this method must be justified by risk assessment.
Suppliers of raw materials for packaging companies seldom have the certificates mentioned earlier, so we are left with either the audit or the questionnaire. It is not always possible to conduct the audit, for example, because of the location of the supplier in the different country or even in different continents, so the questionnaire may be the only choice, and that is why it is the most often used option. But we must remember that if questionnaires were used during the initial approval, they must be reissued at agreed intervals based on risk. Most non-conformities are connected with this clause. If the companies approve its suppliers based on a questionnaire, it is often not justified. Another big challenge is the requirement that the supplier must implement the effective traceability system. Additionally, it shall be ensured that the suppliers have the system.
The verification of the supply traceability system causes the biggest problems. If the supplier is GFSI-recognized standard certified, traceability is required by the standard, and it is verified during the external audit. If the company is not certified but agrees to the audit, it can be verified on-site. However, the questionnaire is the most popular method, as I've mentioned before, yet not the best because traceability system questions must be additionally included in it, and the answer must be obtained. When the supplier has been approved based on the questionnaire instead of certification or audit, verification of supplier's traceability system shall be carried out on the first approval and then at least every three years. This may be achieved by the traceability test. But please note that the traceability test may be one of the methods used. There is a lot of additional information in the interpretation guidance.
I highly recommend you to have a look at the document. The next big issue is supplier approval and performance monitoring where raw materials are purchased from agent, broker, or wholesaler. In this case, the site shall know the identity of the last manufacturer or packer unless the agent, broker is certified to the relevant global standard or relevant standard benchmarked by GFSI, and again, because the agent, broker, or wholesaler are seldom certified to the above standards, additional actions must be taken to obtain information about the last manufacturer or packer. System to minimize the risk of purchasing fraudulent raw materials is required. Different sources of information may be used that allow to identify threats to the supply chain to assess the potential risk of substitution of the raw materials. These can be any trade associations or government sources or any private source centers.
Examples of materials that are identified as being at risk. This may be any premium or high-value materials like color master batches, special materials for decoration, or virgin materials, or biodegradable materials, or raw materials with FSC marks, or any other materials that can be easily substituted. In case of such materials, appropriate control measures shall be established, like assessment performed at suppliers, approval based on history or required certificate of analysis with every delivery, or on-site testing, whatever. Whichever control it would be, it must be reviewed annually. First of all, vulnerability assessment for all raw materials or groups of raw materials has to be prepared to assess the potential risk of substitution based on available information, then find the material that are identified as being at risk. Then establish proper control measure and review them annually. Because it is a completely new requirement, it often causes problems.
There are many non-conformities connected with the fact that not all raw materials were assessed. The key change related to traceability is that where rework or any reworking operation is performed or outsourced or subcontracted activities are carried out, traceability shall be maintained, and traceability of test data and samples to production lot shall be maintained. And generally, suppliers of raw materials shall have an effective traceability system as well, as I told you before, and the verification of the supplier's traceability system causes the biggest problems. Taking into account the company internal traceability system, the most common problems are connected with the fact that not all raw materials are included in the system or batch numbers are wrongly recorded.
Each time during the audit, the auditor is obliged to perform traceability tests on a randomly taken sample, and during that test, system imperfections are often discovered and non-conformities are raised. Problems are also caused by the microbiological environmental monitoring program. The program shall be in place to ensure that cleaning operations are effective in minimizing the risk of product contamination. The program shall consider the likelihood of the microorganism survival on packaging materials and their use. The potential products that we may consider as good environment for survival of microorganisms are, for example, sausage casings as they are produced wet, or products made of natural materials such as wood, cork, or cotton, but also paper and paper products. So microbiological environmental monitoring program shall be based on risk. Appropriate control limits shall be defined, and programs shall be reviewed.
The most recurring non-conformities concern the fact that there is no program at all or it is incomplete and can miss some required elements such as sampling protocol or the identification of sample location, frequency of test, target organisms or test methods, or results and evaluation. There are a few new requirements for pest management that cause a lot of problems. Pest activity throughout different seasons should be analyzed because it can change during the year. In Europe, for example, we can observe increased pest activity in autumn and decrease in winter. The number and frequency of inspections should be justified to it, and additional measures to prevent birds and flying mammals should be implemented and have often been omitted in the implementation. As regards clause 5.4, process control, the most frequent non-conformities concern the lack of control over equipment settings.
That means that the changes to the equipment settings must be completed by trained and authorized staff and password protected or otherwise restricted if there is a high risk of such unauthorized interference. Another problem is dry clearance procedure. More stringent requirements have been established because during all changeover or changes of the products, the risk of mixing is the highest. That's why raw materials, packaging materials, all documents, work orders, and description of the products must be strictly controlled. Before starting a new order, the line must be cleared, and this fact should be recorded. There are often problems because the line is not fully cleared, and some materials or documents remain, and they can cause mistakes or confusion of artwork or products. Another big challenge is a new requirement connected with the validation of test methods used for product inspection.
We must remember that the test methods used by the site in both online and offline testing shall be validated to ensure their sensitivity, reproducibility, and range. It especially concerns company methods which were defined internally based on their company experience or are required by the customer, but not based on commonly approved international standards. In such cases, validation of methods must be performed and recorded. Additionally, where testing shows out-of-specification results, a documented procedure for investigating these results shall be established and followed to determine whether the cause is non-conforming product or testing failure. Another problem is automated inspection equipment, for example, vision systems installed in the printing machines. It is necessary to ensure that it is correctly set up and capable of alerting or rejecting the packaging when it is out of specification.
As a minimum, testing of the equipment shall be completed at the start of the production run, at the end of the production run, and during production if necessary. Procedures for inspection of such equipment are required, as well as procedures in the event of failure in the equipment. Generally, companies which have such equipment perform tests but do not have clearly defined procedures, which may result in raising non-conformities during the audit. The last mandatory clause in the standard concerns personnel. In Issue 6, there weren't many changes. However, auditors identified many non-conformities connected mainly with the lack of required records from trainings or insufficient level of hygiene, for example, wearing jewelry, carrying personal items in production area, bringing in food or prohibited drinks, and inappropriate clothing. I must admit that such non-conformities happen often and are difficult to eliminate because they are part of the personnel behavior.
The implementation of safety culture can help a lot, and of course, promotion of safe behavior among all employees. Clause 7 concerning traded products is not mandatory. It is still a voluntary requirement, but not additional voluntary model any longer. If the company conducts activity in traded products, they have two options: to apply requirements included in this clause and certify the whole activity, or not cover traded products within certification, but then it must be recorded as an exclusion from the scope. As you probably remember, in this case, the company can still use BRCGS logo. That's all from me. Thank you very much for your attention. If you have any questions, you can enter them now into the Q&A box.
Lovely. Thank you very much, Dorota.
That was a great insight into the impact of the changes of Issue 6 over the last 12 months with some really interesting data. So just before we go into the Q&A session, just a quick reminder for everybody, please could you look out for the request and answer our post-event survey? That would be very much appreciated. So now going into the Q&A, I can see there are some very interesting questions coming in. If you have any, obviously, please feel free to submit them. We will do our best to answer all of them, and any that we don't get to, we will certainly respond to after the event. So if I just have a look. Okay, so Dorota, so the first one, regarding supplier approval criteria, what certificates are recognized by the GFSI?
Okay, yes.
So currently, as for packaging, we have a choice of BRCGS or FSSC 22000 or IFS or SQF, so these four. And of course, more information you can find on the GFSI website, so please have a look at the website. There are quite interesting information on it.
Okay. Fantastic. Thank you very much. Another one, how can we verify the supplier's traceability system?
Oh, yes. The traceability system, it is a challenge, I have to say, especially where the supplier has been approved based on a questionnaire instead of a certification or an audit. So we can do it based on traceability tests, but in fact, the test is not the only one method. As I told you during the presentation, there is a really very good interpretation guidance, and you can find there quite, again, good information.
You can find there that there are other methods that can be used for traceability testing system for suppliers. One of them is worked examples from the raw material supplier, which clearly explain the process, the traceability process. The other is a detailed description of the traceability system provided by the material supplier. I think the last one, so this detailed description of the traceability system is the easiest to achieve. Probably, again, it will be the most popular method. Again, I highly recommend you to have a look at the interpretation guidelines. You can find there information about that.
Okay. Fantastic. Thank you very much. I hope that helped to answer that question. I've got one here. Can you please differentiate between a subcontractor and outsourcing?
Yes. Subcontractors and outsourced processes.
Subcontracted activities, it is a process that is carried out at another site on behalf of the certified site, but the material goes off-site to be processed and stays off-site. However, the outsourced process, this is a step in the process which is completed somewhere else, so in the other company, and where the intermediate production process or step in the manufacturing of the product is carried out at another company and returned to the original site. This is the difference. Subcontracted activities, this is when the materials go off-site and stay off-site. Outsourced processes, it's when it goes off-site and returns to the original site to be completed. Okay?
Yes. No, perfect. That does sometimes cause quite a lot of confusion, doesn't it?
Yes. Yes, it is. Yes, absolutely. I agree.
A question here that I can take on to do with the effective implementation of the quality and safety culture. So just on that one, there's lots of things that can be done to implement a product safety culture. And there are many ideas, including team events, social gatherings, involving the team in writing new procedures, idea gathering, team meetings, regular consultations, keeping the team, regardless of the sort of departments or the areas that they work in, keeping them updated and involved in trend analysis so they can actively participate with solutions. Even friendly competitiveness between sites or departments can have a very positive impact on team spirit and motivation. And it all just goes a really long way to a positive product safety culture.
It is important to achieve the requirements of the standard, to have a documented plan in place, which is reviewed on a regular basis, what works well and what doesn't work well with timelines and any sort of future improvements, and just as a note, I briefly touched on it earlier, but SGS have a product, SGS Realize, which is a new product safety culture module. This can take place without auditor interaction and is separate to any audit, so it helps you assess the culture in your business and can be measured year on year, so this brochure is actually now available to download from the SGS website, so hopefully, that has answered that question. Another one for you, Dorota. If a supplier is certified to a third-party ISO standard and we approve using a questionnaire, does traceability still need to be confirmed at first approval?
Yes. Okay.
So yes, the traceability system still must be confirmed at the first approval. However, it can be quite easy, much more easier than if the company is not certified at all. So in fact, if there is a certificate, even if this is an ISO 9000 certificate, it will be much easier. So probably, we can ask the supplier just to describe the traceability system that is on-site. Yes. Okay.
Okay. Fantastic. And hopefully, a fairly straightforward one. Can you please give examples of traded products?
Traded products. Okay.
So I mean, I can jump in, not necessarily specific examples of products.
Yeah. Maybe.
Sorry, sorry, Dorota. Did you want, yeah, I can jump in. Not necessarily a specific example of a traded product, but a traded product is a product that you don't manufacture yourselves on-site, so you buy the products in supplementary parts of it.
So it can be any different products, but it must be packaging. Yes. So any kind of packaging that is bought by the company itself, by the company as well. So it can be everything, but it must be packaging. Yeah.
Perfect. Yep. No, perfect. Packaging, oh, no, I'm not sure if I understand correctly. Packaging supplier assessments and audit guidelines. That's probably something we just have to look into a little bit on that one. It's asking if we can share. So why has the hazard and risk management been split into two different points?
Okay. So yes, in this new version of the standard, we have, in fact, risk assessments in two different places, two different clauses. One is in .22 . And in this particular clause, we evaluate hazards related to product safety and legality.
And in fact, we should also identify control measures that should be implemented. It can be also a critical control point, including in the control measures. However, in the 5.4 , yes, process control, we have to evaluate hazards related to quality only. And control measures should be based on GMP and prerequisite programs. So the difference between the product safety and legality issues versus quality issues, let's say. So it is to help the companies to understand the difference between this product safety and legality issues versus the quality issues. So I think that's it. Okay. Thank you.
Yes. Very comprehensive. So for those of us not yet certificated to the BRC Global Standard, how can we access the guidance document?
It is, in fact, free. Free guidance. You can find it on the BRCGS website.
So if you open BRCGS website, you can choose the packaging material standard. And there are published some information. For sure, there is a checklist. For sure, there are additional position statements. So it's quite many additional documents available there.
Fantastic. And just a confirmation, actually, on one of your last answers. So just to confirm, products that are not packaging materials but stored in our warehouse for distribution elsewhere do not count as traded goods?
No, no. If this is, if the company trades some products that are not packaging materials, it should not be mentioned in the scope. So this is completely different. So only products that are packaging materials should be taken into account when implementing and certifying the BRC Packaging Material Standard.
Yeah. Fantastic. And just to add to that one, it may be that another BRCGS standard will cover those products.
Oh, yes. Yes. Sure.
Yeah. No, no. It's fine, so it's not covered by packaging, but should it be something that you want it to be covered by BRCGS? Then if you sort of contacted SGS, we could give you the advice as to which standard is the most appropriate, but another question. If we make a product for a customer and use their packaging with their brand name, what are the requirements or controls required for their packaging?
Under the brand name, yes?
Yes.
Okay, so in fact,
if you want to get too lengthy, we can come back to it, but if.
Yes. Yes. We can come back maybe in detail later.
But generally, if there is a brand name on the packaging, so there is a requirement to control this brand name and have an agreement with companies who is the owner of this brand name. And in the agreement, there should be some information on how to control the brand name. So this is quite important, especially during, of course, the printing process. And if we have some products printed already and there are waste, for example, because of some quality problems, what to do with this particular waste with the brand name on it? So this is quite important. But of course, I can put maybe more information in the email and send. Okay.
Okay. Fantastic. So another question. History on fraud in packaging. What other public sources are there which are similar to the RASFF sort of guidelines?
Are there any sort of other well-known sources where we can get this information from?
Okay. So again, I would like to ask you to have a look at the Position Statement . As I told you during the presentation, there is one position statement now, including all the information. This is Position Statement P618. And you can find there really very helpful information about food defense and food fraud. So please have a look at the document. There are quite many sources of information about that. Usually, it is some government information. So it differs in different countries. So you have to, again, have a look at some government pages, websites, and try to find some information. But please have a look at the Position Statement .
Okay. Fantastic. Thank you. And I know that do customers still have to audit their suppliers that are BRCGS certified?
Do customers still have to audit suppliers? No, in fact, it is one of the criteria that can be applied. It is not the only one, so you can evaluate, let's say, your supplier based on certification, based on certificates, or based on the audit, or based on the questionnaire, so we have, in fact, three methods to apply, so the audit is not the only one method, so it is not necessary to do always the audit.
Yeah. Perfect. Thank you very much. And the BRCGS certification is specific to a particular manufacturing site. Whether there is a multi-site or audit option available, wherein if the scope is the same for a company but multiple locations, then can the BRCGS audit be done on a sample basis for certification purposes? That's quite a lengthy one, so it's about multi-sites, and if we can sample multiple locations.
In fact, sampling of the location is not possible in BRC. So if we want to certify the multi-site, so every site must be visited, but it must be very clearly stated in the report and in the scope what exactly processes are run in each location. So it is not like in quality standards. Unfortunately, not. We have to be sure that in every location and in every site, the processes are correct and the products are safe for the consumer, for the next user. Yeah. Okay.
Yeah. 100%. And the rules for multi-sites can be the specific rules and the details for multi-sites can be seen in the standards. But yeah. Yeah. No, that's fantastic. And I think we've probably got time for one more question. So if the agent and broker are online traders and doesn't have a certificate, but the manufacturing company does, is this sufficient?
Okay. So that's a bit broad, maybe. If the agent and broker are online traders and all, that is. So in fact, we have to know that the requirement is that we have to know the last manufacturer or packer if the raw materials are purchased from agent or broker. So in fact, it is important for us just to know the name of the last manufacturer or packer. Yes. This is what the standard requires.
Okay. Fantastic. Just a couple more questions, but I think we're coming to the end of the hour. So what we'll do, any questions that we haven't had an opportunity to answer, we will certainly get back to everybody. So yeah, thank you very much, Dorota, and drawing this webinar to an end, many thanks to you all for listening and for the questions that have been submitted.
And, as I say, if we haven't managed to answer, then we'll get back to you after the event is closed. I hope this event and webinar has given you some valuable information and learnings over the last 12 months, effectively the first year for Packaging Issue 6. And yeah, thank you again for listening.
Thank you very much once again. Thank you very much.