BRCGS V9 -5.4- Product authenticity, claims and chain of custody

• Conducted on

  Date

• Prepared by

• Location
  Address

• Auditor's signature : I agree with the audit findings

  Sign

• Auditee's name

• Auditee's Job title

• SOI<br>Systems shall be in place to minimise the risk of purchasing fraudulent or adulterated food raw materials and to ensure that all product descriptions and claims are legal, accurate and verified.

  Compliant

  Minor

  N/A

  Major

  Critical

5.4.1 Personel's competence in V.A.C.C.P

• Where personnel are engaged in vulnerability assessments, the individual or team responsible shall understand potential food fraud risks.

  Compliant

  Minor

  N/A

  Major

  Critical

• This shall include knowledge of raw materials used by the site and the principles of vulnerability assessment.

  Compliant

  Minor

  N/A

  Major

  Critical

5.4.2 Sources of information on V.A.C.C.P.

• The company shall have processes in place to access information on historical and developing threats to the supply chain which may present a risk of adulteration or substitution of raw materials (i.e. fraudulent raw materials).

  Compliant

  Minor

  N/A

  Major

  Critical

• Such information may come from, for example:

• trade associations

  Compliant

  Minor

  N/A

  Major

  Critical

• government sources

  Compliant

  Minor

  N/A

  Major

  Critical

• private resource centres

  Compliant

  Minor

  N/A

  Major

  Critical

• activities completed for clause 1.1.8.

  Compliant

  Minor

  N/A

  Major

  Critical

5.4.3 Documented vulnerability assessment

• A documented vulnerability assessment shall be carried out on all food raw materials or groups of raw materials to assess the potential risk of adulteration or substitution.

  Compliant

  Minor

  N/A

  Major

  Critical

• This shall take into account:

• historical evidence of substitution or adulteration

  Compliant

  Minor

  N/A

  Major

  Critical

• economic factors which may make adulteration or substitution more attractive

  Compliant

  Minor

  N/A

  Major

  Critical

• ease of access to raw materials through the supply chain

  Compliant

  Minor

  N/A

  Major

  Critical

• sophistication of routine testing to identify adulterants

  Compliant

  Minor

  N/A

  Major

  Critical

• the nature of the raw material.

  Compliant

  Minor

  N/A

  Major

  Critical

• The output from this assessment shall be a documented vulnerability assessment plan.

  Compliant

  Minor

  N/A

  Major

  Critical

• This plan shall be kept under review to reflect changing economic circumstances and market intelligence which may alter the potential risks.

  Compliant

  Minor

  N/A

  Major

  Critical

• It shall be reviewed annually and whenever there is:

  Compliant

  Minor

  N/A

  Major

  Critical

• a change in raw materials or a supplier of raw materials

  Compliant

  Minor

  N/A

  Major

  Critical

• emergence of a new risk (e.g. known adulteration of an ingredient or developments in scientific information associated with authenticity of the site’s products or raw materials, for example, information obtained as part of clause 1.1.8)

  Compliant

  Minor

  N/A

  Major

  Critical

• following a significant product safety incident (e.g. a product recall) where the authenticity of the site’s products or raw materials is implicated.

  Compliant

  Minor

  N/A

  Major

  Critical

5.4.4 Assurance and/or testing processes

• Where raw materials are identified as being at particular risk of adulteration or substitution, the vulnerability assessment plan shall include appropriate assurance and/or testing processes to mitigate the identified risks.

  Compliant

  Minor

  N/A

  Major

  Critical

5.4.5 Pack Claims

• Where products are labelled or claims are made on finished packs which are dependent on the status of a raw material, the status of each batch of the raw material shall be verified. These claims include:

  Compliant

  Minor

  N/A

  Major

  Critical

• specific provenance or origin

  Compliant

  Minor

  N/A

  Major

  Critical

• breed/varietal claims

  Compliant

  Minor

  N/A

  Major

  Critical

• assured status (e.g. GLOBALG.A.P.)

  Compliant

  Minor

  N/A

  Major

  Critical

• genetically modified organism (GMO) status

  Compliant

  Minor

  N/A

  Major

  Critical

• identity preserved

  Compliant

  Minor

  N/A

  Major

  Critical

• named specific trademarked ingredients.

  Compliant

  Minor

  N/A

  Major

  Critical

• The facility shall maintain purchasing records, traceability of raw material usage and final product packing records to substantiate claims.

  Compliant

  Minor

  N/A

  Major

  Critical

• The site shall undertake documented mass balance tests at a frequency to meet the particular requirements of any scheme it is certificated to, or in the absence of a scheme-specific requirement, at least one mass balance test every 6 months.

  Compliant

  Minor

  N/A

  Major

  Critical

5.4.6 Method of production claims

• Where claims are made about the methods of production (e.g. organic, halal, kosher), the site shall maintain the necessary certification status in order to make such a claim.

  Compliant

  Minor

  N/A

  Major

  Critical

5.4.7 Validation of product claims

• Where a product is designed to enable a claim to be made, the company shall ensure that all claims are substantiated, and product formulation and the production process are fully validated to meet the stated claim and any legal requirements (in the country of intended sale) relating to the claim.

  Compliant

  Minor

  N/A

  Major

  Critical

• The process flow (see clause 2.5.1) for the production of products where claims are made shall be documented and potential areas for contamination or loss of identity identified.

  Compliant

  Minor

  N/A

  Major

  Critical

• Appropriate controls shall be established to ensure the integrity of the product claims.

  Compliant

  Minor

  N/A

  Major

  Critical