Packaging Certifications: BRC, ISO, FDA — What You Need to Know

Why certifications matter in the packaging industry?

In the packaging industry, certifications are not prestige decorations on an office wall — they are a necessary condition for participation in the professional supply chain. Large retail chains, international food manufacturers, and pharmaceutical companies will not accept packaging from a manufacturer that does not hold appropriate certificates.

The reasons are obvious: packaging has direct contact with the product that reaches the consumer. Defective packaging can lead to:

• Food contamination — migration of substances from packaging to product (plasticizers, solvents from printing inks, heavy metals)

• Quality loss — insufficient barrier leads to food spoilage

• Physical hazard — material fragments, mechanical contaminants

• Product recall from market — cost reaching millions and irreparable reputation loss

Certifications guarantee that the packaging manufacturer has implemented systems minimizing these risks.

BRC Packaging Materials — The Gold Standard of the Packaging Industry

What is BRC Packaging?

BRC Packaging Materials (Issue 7, effective from 2024) is a standard developed by BRCGS (Brand Reputation through Compliance Global Standards, formerly British Retail Consortium). It is the most widely recognized certificate in the packaging industry worldwide, accepted by over 30,000 facilities in 130 countries.

Paczki na Wymiar holds the BRC Packaging certificate, confirming the highest quality and safety standards of our packaging.

6 Key Areas of BRC Audit

1. Senior Management Commitment

Management must demonstrate active engagement in safety and quality:

• Defined quality and product safety policy

• Appointed product safety team with competencies and resources

• Regular management reviews (at least annually)

• Food safety culture — awareness at all organizational levels

2. Hazard and Risk Management System (HARA)

Hazard and Risk Analysis — the packaging equivalent of HACCP:

• Identification of biological, chemical, and physical hazards at every production stage

• Risk assessment and determination of control measures

• Monitoring of critical control points (e.g., lamination temperature, seal quality)

• Corrective procedures in case of deviations

3. Quality and Safety Management System

• Documented procedures for all critical processes

• Control of raw material and finished product specifications

• Allergen management (in the context of packaging for food with allergens)

• Material authenticity and traceability — from raw material to finished product

4. Production Facility Standards

• Infrastructure requirements: floors, walls, ceilings, lighting

• Pest management

• Personnel hygiene — protective clothing, hand washing, policy on jewelry and personal items

• Foreign body control — metal detectors, X-ray inspection (where required)

5. Product and Process Control

• Incoming raw material control — certificates, testing

• Process control — printing, lamination, cutting, sealing parameters

• Finished product control — strength tests, barrier tests, migration tests

• Non-conformance and complaint management

6. Personnel

• Product safety and hygiene training

• Technical competencies at key positions

• Supervision of temporary workers and subcontractors

How does the BRC audit work?

The BRC audit process consists of several stages:

1. Selection of certification body — accredited by BRCGS (e.g., SGS, Bureau Veritas, Lloyd's Register)
2. Certification audit — auditor visits the facility for 2-5 days (depending on size)
3. Audit report — list of non-conformances (major, minor, critical) and observations
4. Non-conformance correction — manufacturer has 28 calendar days to close major and minor non-conformances. A critical non-conformance results in audit failure
5. Certification decision — grade assigned (AA, A, B, C, D) based on number and type of non-conformances
6. Recertification — every 12 months (option: unannounced audit, rewarded with higher grade)

BRC Grade	Number of Non-conformances	Meaning
AA	≤5 minor, 0 major	Outstanding
A	6-10 minor, 0 major	Very good
B	11-16 minor, 0 major OR ≤10 minor + 1 major	Good
C	17-24 minor OR ≤16 minor + 1-2 major	Satisfactory
D	Not certified	Not awarded

Benefits of BRC Certificate

• Market access — required by Tesco, Lidl, Aldi, Carrefour, and hundreds of other chains

• GFSI recognition — accepted globally by all companies recognizing GFSI standards

• Reduced customer audits — instead of 10 audits from 10 customers, one BRC audit accepted by all

• Process improvement — systematic approach to quality and safety reduces complaints by 30-50%

• Competitiveness — differentiator in the market, especially in export

Read more about food packaging and food contact in our complete guide to flexible packaging.

ISO 9001 — Quality Management

Scope and Requirements

ISO 9001:2015 is an international quality management system (QMS) standard used in all industries. It is not specific to packaging but forms the organizational foundation:

• Organizational context — understanding the business environment, needs of interested parties

• Leadership — management commitment, quality policy

• Planning — risk and opportunity management

• Support — resources, competencies, communication, documented information

• Operational activities — planning and supervision of processes

• Performance evaluation — monitoring, measurements, internal audit

• Improvement — non-conformances, corrective actions, continuous improvement

ISO 9001 vs. BRC — Do you need both?

Aspect	ISO 9001	BRC Packaging
Scope	General quality management	Packaging safety and quality
HACCP/HARA	Not required	Required
Facility hygiene	General requirements	Detailed requirements
Food contact	Not addressed	Key element
GFSI recognition	No	Yes
Customers	All industries	Retail chains, food manufacturers
Certification cycle	3 years (+ surveillance audits)	12 months

In practice: BRC covers and exceeds most ISO 9001 requirements in the packaging context. If your market is food and retail chains, BRC is the priority. ISO 9001 is useful as a supplement for customers outside the food sector.

ISO 22000 — Food Safety

How is it different from BRC?

ISO 22000:2018 is an international food safety standard based on HACCP principles. In the packaging context, it is an alternative to BRC, recognized by GFSI (in the FSSC 22000 version):

• HACCP principles — 7 principles, 12 implementation steps

• Prerequisite programs (PRP) — equivalent to BRC infrastructure requirements

• Process approach — consistent with ISO 9001 (HLS — High Level Structure)

• Communication — requires communication in the food chain (suppliers, customers, control authorities)

FSSC 22000 — GFSI Recognized Version

ISO 22000 alone is not recognized by GFSI. To obtain GFSI recognition, a packaging manufacturer must implement FSSC 22000 (Food Safety System Certification), which includes:

• ISO 22000:2018 — food safety management system

• ISO/TS 22002-4:2013 — prerequisite programs for food packaging production

• Additional FSSC requirements (service management, labeling, food defense)

FDA Requirements — Export to USA

FDA Regulations for Packaging

Food and Drug Administration (FDA) regulates food packaging in the USA through 21 CFR (Code of Federal Regulations):

• 21 CFR 174-179 — substances permitted in food contact (indirect food additives). Each packaging material ingredient must be listed in the appropriate CFR section or have an FCN (Food Contact Notification)

• 21 CFR 110 — GMP (Good Manufacturing Practice) requirements for facilities

• FSMA (Food Safety Modernization Act) — requires importers to verify that the foreign manufacturer meets FDA standards

Practical Requirements for Polish Manufacturers Exporting to USA

1. FDA facility registration — every facility producing materials for food contact must be registered in the FDA system. Registration is free and requires renewal every 2 years
2. Letter of Compliance (LOC) — document confirming that materials meet 21 CFR requirements. LOC is issued by the packaging material manufacturer based on migration testing
3. Migration testing — tests confirming that substances from packaging do not migrate into food above permitted limits
4. FSVP (Foreign Supplier Verification Program) — US importer must verify that the foreign supplier meets safety standards

FDA vs. EU Regulations — Key Differences

Aspect	FDA (USA)	EU
Approach	Positive list (permitted substances)	Framework + positive list
Global migration	Not directly regulated	Max 10 mg/dm²
Specific migration	Limits per substance	Limits per substance (SML)
Facility certification	Registration + GMP	No central requirement
Supervision	FDA inspections (may be unannounced)	National inspections (Sanepid)

EU Regulations on Food Contact

Framework Regulation (EC) 1935/2004

The basic EU legal act for materials in contact with food (FCM — Food Contact Materials):

• Materials must not transfer substances in quantities endangering health

• Materials must not cause unacceptable changes in food composition

• Materials must not deteriorate organoleptic properties of food

Regulation (EU) 10/2011 — Plastics

Detailed regulations for plastics in contact with food:

• Positive list — only substances listed in Annex I may be used

• Global migration limits — max 10 mg/dm² of packaging surface

• Specific migration limits (SML) — for individual substances (e.g., BPA: 0.05 mg/kg, phthalates: 1.5 mg/kg)

• Food simulants — migration tests are conducted using simulants (ethanol, acetic acid, oil) corresponding to different food types

Declaration of Compliance (DoC)

Every food packaging manufacturer must provide a Declaration of Compliance confirming:

• Compliance with Regulation 1935/2004 and 10/2011

• Migration test results

• Conditions of use (temperature, contact time, food type)

• Raw material traceability

Read more about ecological aspects of packaging and environmental regulations in our article on eco-friendly packaging trends.

Environmental Certifications — Growing Importance

FSC and PEFC

Certifications confirming that paper and cardboard in packaging come from responsibly managed forests:

• FSC (Forest Stewardship Council) — most recognizable, required by many retailers

• PEFC (Programme for the Endorsement of Forest Certification) — alternative, popular in Europe

OK Compost / Seedling

Certifications for biodegradable and compostable packaging:

• OK Compost Industrial — packaging decomposes in industrial composting facility (>58°C) within 12 weeks

• OK Compost Home — packaging decomposes in home compost bin (ambient temperature)

Recyclass

Assessment system for plastic packaging recyclability:

• Class A — fully recyclable in existing infrastructure

• Class B — recyclable with minor limitations

• Class C — technically recyclable but infrastructure is limited

Paczki na Wymiar Certifications

Paczki na Wymiar holds the following certificates and approvals:

• BRC Packaging Materials — certificate confirming the highest safety and quality standards for packaging

• ISO 9001:2015 — quality management system

• Compliance with Regulation (EU) 10/2011 — materials approved for food contact

• FDA Declarations — materials compliant with 21 CFR requirements for export to USA

Our certificates mean that by choosing Paczki na Wymiar as your packaging supplier, you receive a product verified by independent auditors, meeting the requirements of the world's most rigorous retail chains and food manufacturers.

Read more about our packaging for the cosmetics and supplement industry, where certifications play a particularly important role, in our article on cosmetics and supplements packaging.

Summary: Which certificate to choose?

The choice of certificate depends on your target market and customer requirements:

• Selling to retail chains in Europe? → BRC Packaging (priority) + ISO 9001

• Exporting to USA? → FDA Registration + LOC + BRC (accepted by US retailers)

• Serving the food industry? → BRC or FSSC 22000 + Declaration of Compliance (EU) 10/2011

• Serving non-food industries? → ISO 9001 as minimum

• Care about ecological image? → FSC/PEFC + Recyclass

Need packaging with full certification documentation? At Paczki na Wymiar, we deliver not only packaging but complete documentation: Declarations of Compliance, BRC certificates, migration specifications, and LOC for export to USA.

Contact us — we'll prepare packaging with complete quality documentation.