Packaging rarely causes food safety audits to fail outright — but it is a frequent driver of extended audits, escalated findings, and repeat non-conformances.
Across food safety audits conducted under GFSI-recognised schemes (including BRCGS, IFS, and FSSC 22000), packaging-related findings continue to appear with striking regularity. In aggregated audit observations, packaging issues are involved in approximately 30–40% of audits where additional verification, corrective actions, or extended audit time is required.
Not because teams ignore packaging — but because documentation gaps, scope ambiguity, and late changes intersect under audit pressure. Understanding these patterns helps Quality Managers anticipate where audits most often slow down or escalate.
Packaging risks are predictable — and audit-linked
Packaging non-conformities are rarely random. They tend to follow repeatable patterns linked to:
- how packaging is integrated into the food safety system
- how suppliers and materials are validated
- how changes are documented
- how evidence is presented during audits
When these elements are misaligned, auditors spend more time reconciling information — and findings escalate.
1. Outdated or incomplete Declarations of Compliance (DoCs)
What auditors flag
Auditors frequently identify packaging materials in use where:
- Declarations of Compliance are missing or outdated
- Intended use conditions are unclear
- Regulatory references are incomplete or generic
Under BRCGS Packaging Materials and FSSC 22000 (ISO 22000 + PRPs), current and product-specific DoCs are expected to be readily available.
Why this still happens
Packaging documentation is often treated as a supplier-managed file, with limited internal verification unless a change occurs.
Audit impact
In practice, DoC gaps are among the most common packaging-related minor findings and a frequent contributor to repeat non-conformances when not addressed systematically.
2. Packaging scope not clearly defined or aligned
What auditors flag
Common findings include:
- packaging activities not fully included in audit scope
- unclear responsibility for outsourced or third-party packaging
- inconsistencies between food safety scope and packaging scope
These issues are often assessed under BRCGS clauses related to scope and site activities or equivalent FSSC requirements on system definition.
Why this still happens
Scope descriptions often reflect legacy operations, not current realities — especially after growth, outsourcing, or supplier changes.
Audit impact
Scope-related packaging issues are a frequent cause of extended audit discussions and follow-up actions, particularly in multi-site operations.
3. Weak traceability for packaging components
What auditors flag
Traceability exercises frequently demonstrate:
• strong ingredient traceability
• limited or inconsistent traceability for packaging materials
Auditors may request demonstration of packaging traceability during recall scenarios, in line with GFSI traceability expectations and BRCGS traceability clauses.
Why this still happens
Packaging traceability is often considered secondary to ingredient traceability, even though it is equally critical during investigations.
Audit impact
In aggregated audits, traceability gaps are one of the most common escalation points, where minor findings become major due to inability to demonstrate control during the audit.
4. Packaging changes not fully risk-assessed
What auditors flag
Non-conformances arise when:
- packaging materials are changed (often for sustainability reasons)
- suppliers are replaced
- materials are reformulated
without documented food safety risk assessment, contrary to change management expectations under BRCGS and FSSC.
Why this still happens
Packaging changes are frequently driven by commercial or sustainability objectives, with food safety validation following later — or remaining implicit.
Audit impact
Change-related gaps are a common driver of repeat findings, especially where sustainability initiatives outpace system updates.
5. Gaps between documented procedures and real practices
What auditors flag
Auditors observe:
- packaging stored outside defined zones
- hygiene practices not aligned with procedures
- staff unclear about packaging handling requirements
These observations are often assessed under GMP / hygiene clauses rather than packaging-specific sections.
Why this still happens
Packaging handling is often perceived as low-risk, leading to less consistent training and oversight.
Audit impact
Observation-based findings are among the most difficult to defend, as they challenge overall system effectiveness.
6. Packaging not adequately covered in internal audits
What auditors flag
Internal audit programmes sometimes:
- focus heavily on ingredients and processing
- give limited attention to packaging controls
This conflicts with GFSI expectations that internal audits cover all relevant risk areas.
Why this still happens
Packaging is often assumed to be “covered elsewhere” rather than audited explicitly.
Audit impact
Packaging gaps first identified during external audits are a frequent cause of corrective action overload post-audit.
Why some packaging findings escalate from minor to major
In packaging audits, escalation often depends less on the issue itself and more on the evidence trail:
- Missing or outdated documentation may start as a minor
- Inability to demonstrate control, validation, or traceability during the audit can escalate the same issue to major
This pattern is particularly common where food contact materials, supplier responsibility, or traceability are involved.
Audit impact we commonly observe
Based on aggregated audit observations across food manufacturing sites:
- Packaging-related gaps contribute to extended audit duration in a significant share of audits
- Documentation and scope issues are among the top drivers of repeat non-conformances
- Late clarification of packaging controls often leads to additional corrective actions after the audit
These patterns appear consistently across audits conducted against BRCGS, IFS, and FSSC 22000, where packaging is assessed as part of overall system effectiveness.
Why awareness matters
Quality Managers who recognise these non-conformity patterns early can:
- anticipate auditor focus areas
- reduce last-minute corrective actions
- protect teams during peak audit periods
Awareness is not about blame — it is about anticipation and control.
Final thought
Packaging non-conformances often feel “unexpected” — but they follow predictable, audit-linked patterns.
Understanding what auditors most commonly flag allows Quality Managers to shift packaging from a reactive risk to a controlled part of the food safety system, well before audit pressure peaks.
Want to explore this topic in more depth?
For Quality Managers who want a deeper technical walkthrough of how packaging systems are assessed in practice, this topic is covered in more detail in our on-demand webinar on packaging compliance and audit expectations.
Watch the on-demand packaging compliance webinar
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