Product Labeling
Aligned with FSSC 22000
Requirement Overview
FSSC 22000 requires that all product labels are accurate, approved, and correctly applied to protect consumers and meet legal, regulatory, and customer-specific requirements.
Incorrect labeling—especially related to allergens or claims—is a critical risk that can lead to product recalls, consumer harm, and non-conformances during audits.
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
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✓ Verify that all product labels meet legal and customer requirements
✓ Prevent the use of incorrect, outdated, or unauthorized labels
✓ Ensure label accuracy for allergens, ingredients, and claims
✓ Maintain records of approval and verification
Step-by-Step Compliance Implementation
1. Establish Label Verification and Approval Procedures
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Procedure Should Include:
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• Pre-approval of all label designs and content
• Checks for regulatory, allergen, and customer-specific compliance
• Clear roles and responsibilities for label review and sign-off
Evidence to Maintain:
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• Label approval records with reviewer signatures
• Regulatory and customer requirement checklists
• Current label database or register
- • Pre-approval of all label designs and content • Checks for regulatory, allergen, and customer-specific compliance • Clear roles and responsibilities for label review and sign-off
- • Label approval records with reviewer signatures • Regulatory and customer requirement checklists • Current label database or register
2. Control Label Storage and Usage
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Best Practices Include:
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• Secure storage of printed labels
• Issuance of labels only for approved production runs
• Removal of obsolete labels from production areas
Evidence to Maintain:
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• Label issue logs
• Label inventory and control records
• Obsolete label disposal documentation
- • Secure storage of printed labels • Issuance of labels only for approved production runs • Removal of obsolete labels from production areas
- • Label issue logs • Label inventory and control records • Obsolete label disposal documentation
3. Conduct Pre-Production Label Checks
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Checks Must Include:
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• Correct label applied to correct product
• Accurate product name, ingredient list, allergen declarations, net weight, and date code
• Match to customer specifications and regulatory requirements
Evidence to Maintain:
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• Line start-up check records
• Label verification forms
• Label samples signed by QA or production leads
- • Correct label applied to correct product • Accurate product name, ingredient list, allergen declarations, net weight, and date code • Match to customer specifications and regulatory requirements
- • Line start-up check records • Label verification forms • Label samples signed by QA or production leads
4. Monitor Label Accuracy During Production
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Monitoring Includes:
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• In-line checks for label application, positioning, and legibility
• Verification of batch codes, barcodes, expiry dates, and claims
• Random sampling and visual inspections
Evidence to Maintain:
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• Label verification logs per production shift
• Line inspection reports
• Non-conformance reports (if applicable)
- • In-line checks for label application, positioning, and legibility • Verification of batch codes, barcodes, expiry dates, and claims • Random sampling and visual inspections
- • Label verification logs per production shift • Line inspection reports • Non-conformance reports (if applicable)
5. Address Non-Conformances and Prevent Recurrence
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Required Actions:
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• Isolate mislabeled products
• Conduct root cause analysis
• Apply corrective and preventive measures
Evidence to Maintain:
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• Non-conformance and incident reports
• CAPA records
• Label re-training logs for affected staff
- • Isolate mislabeled products • Conduct root cause analysis • Apply corrective and preventive measures
- • Non-conformance and incident reports • CAPA records • Label re-training logs for affected staff
Common Audit Findings & Recommended Fixes
| Audit Finding | Recommended Action |
|---|---|
| Incorrect allergen declaration | Implement stricter label sign-off and allergen validation checks |
| Outdated label used in production | Remove all obsolete labels from inventory and update document control |
| No evidence of label verification | Use label checklists and maintain signed verification forms |
| Unauthorized label change | Enforce a documented label change control process |
