BRCGS Consumer Products Issue 4 Section 2: Product Risk Assessment, Labelling, Claims and Packaging

By Robert Low, Director, Lead Auditor & BRCGS Approved Trainer

Section 2 of Issue 4 is where the standard asks the most important question in consumer products: is this product safe and legal for the people who will actually use it? It covers keeping up with legislation and safety requirements, the product risk assessment itself, product labelling and claims, and packaging materials. Four related disciplines, one underlying demand: know your product, know your markets, and prove both.

Legislation: Current, Relevant, Evidenced

The expectation is a live system for staying informed of legislation, codes of practice and technical developments in the countries of manufacture and, where known, sale. The finding pattern is predictable: sites subscribe to something, file the updates, and cannot show a single change that resulted. Evidence the loop: the update arrived, someone assessed it, the specification or label or process changed, or a documented decision recorded that no change was needed.

The Product Risk Assessment

The core of the section: a documented assessment per product or product group covering intended use, foreseeable misuse, applicable legal requirements and claims, the levels of risk, and whether each risk is acceptable, done by competent people, reviewed on change and at a defined frequency. Two failure modes dominate. First, the generic assessment: one template stretched across wildly different products until it says nothing about any of them. Second, the frozen assessment: written at launch, never revisited despite reformulations, new markets or complaints that should have triggered review. Foreseeable misuse deserves particular honesty, children get hold of things, products get used undiluted, packaging gets repurposed, and the assessment that ignores this reads as naive to an experienced auditor.

Labelling, Claims and Packaging

Labelling and claims must meet the legal requirements of the country of supply, with controlled artwork approval and re-review whenever the specification, materials, origin or legislation changes. Claims need substantiation you can produce on demand: if the label says dermatologically tested or 99 point 9 percent effective, the file behind it gets opened during the audit. Packaging must protect the product, protect the user and carry the required information, with the supporting evidence, migration, compatibility, suitability, sitting in your technical files rather than in your supplier’s promises.

What Changes Under Issue 5

Issue 5, as per the public draft, merges this section with process risk assessment into a single product and process risk management section built on the HARA methodology, folds legislation monitoring into senior management, and expands technical file expectations. The thinking you do now on risk assessment quality transfers directly, my HARA explainer shows where it is heading. Back to the series hub, or on to Section 3 part 1.