Product Control: Product Release

Aligned with FSSC 22000

Requirement Overview

FSSC 22000 requires that all finished products be held under control until inspection, testing, and verification activities confirm they meet defined food safety and quality criteria. Products must not be released unless approval is granted by authorized personnel.

Product release is a critical control point in the supply chain where failure can result in non-compliant or unsafe food reaching the market.

Aligned with BRCGS for Storage & Distribution Issue 4 – Clause 4.3.1 & 4.3.3

Requirement Overview

BRCGS for Storage & Distribution requires that products moved via cross-docking are traceable and controlled at all times, even when they are not held in storage for extended periods.

Clause 4.3.1: “The company shall ensure that traceability is maintained at all stages, including during cross-docking operations.”
Clause 4.3.3: “Procedures shall be in place to ensure that all products handled, including those not stored on-site, remain under control and are not subject to contamination or substitution.”

Cross-docking operations must not compromise product traceability, safety, or integrity. Even with minimal handling and temporary presence, each product must be accurately identified, documented, and protected.

Key Compliance Objectives

  • ✓ Ensure product is not released until it meets all specifications

    ✓ Assign and document release authority to qualified personnel

    ✓ Maintain records of inspection, testing, and release approvals

    ✓ Prevent release of non-conforming or suspect product

Step-by-Step Compliance Implementation

1. Define Product Release Criteria

  • Release Conditions Include:

    • • Completion of all required inspections and laboratory tests

      • Conformance with finished product specifications (microbiological, chemical, sensory, etc.)

      • Verification of label accuracy, packaging integrity, and code dates

    Evidence to Maintain:

    • • Product specification sheets

      • Completed inspection/test logs

      • Certificates of analysis (if applicable)

2. Assign Release Authority

  • Authorized Personnel May Include:

    • • Quality Assurance Manager

      • Site Technical Manager

      • Designated QA Release Officer

    Control Measures:

    • • Ensure only trained, authorized individuals can approve release

      • Maintain a list of authorized signatories and responsibilities

    Evidence to Maintain:

    • • Product release SOP

      • Authorization and training records

      • Signature verification list

3. Conduct Product Verification Checks

  • Verification May Include:

    • • Sensory checks (appearance, texture, aroma)

      • Lab test results (e.g., allergen, pathogen, moisture content)

      • Packaging, date coding, and traceability validation

    Evidence to Maintain:

    • • Inspection reports or checklists

      • QC sampling results

      • Records of failed/rejected lots and dispositions

4. Record and Approve Product Release

  • Release Documentation Must:

    • • Be signed/initialed and dated by an authorized person

      • Clearly reference batch/lot numbers and test results

      • Include justification for release or hold

    Evidence to Maintain:

    • • Final product release records

      • Retained samples (if applicable)

      • Non-conformance or hold/release forms

Common Audit Findings & Recommended Fixes

Audit Finding Recommended Action
Products released without approval Ensure only authorized personnel are permitted to release product
Missing or incomplete release records Use standardized product release forms and train QA team
Lab tests pending at time of release Implement a hold-and-release protocol with documented verification
No evidence of specification checks Cross-check with product spec sheets and retain inspection results

Auditor Verification Checklist

During an FSSC 22000 audit, expect to present:

  • • Your product release procedure (SOP)

    • A list of authorized release personnel

    • Product release records with batch/lot traceability

    • QC inspection and test results that support each release

    • Records of non-conforming products and resolution

Implementation Roadmap

Build Your Control Framework

  • ✓ Create and approve a product release SOP

    ✓ Define inspection and testing criteria for each product

Assign and Train

  • ✓ Designate release authority to qualified personnel

    ✓ Train QA staff on inspection protocols and documentation

Operate and Monitor

  • ✓ Perform checks consistently for all production batches

    ✓ Record all results, approvals, and non-conformances

Improve Continuously

  • ✓ Review release failures and implement CAPAs

    ✓ Audit the release process to ensure compliance

Why This Matters?

  • ✓ Prevents release of unsafe or non-compliant product

    ✓ Enhances traceability and accountability

    ✓ Reduces regulatory and brand risk

    ✓ Strengthens consumer trust and audit readiness

Support Tools Available

Food Safety Systems provides:

  • ✓ Product release SOP templates

    ✓ Quality inspection and test result logs

    ✓ Release authority tracking forms

    ✓ Product release audit checklists