BRCGS Consumer Products Issue 4 Section 5: Product Inspection, Testing, Quantity and Sample Control

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

Section 5 of Issue 4 is short but carries real weight: product inspection and laboratory testing, quantity control, and product sample control. This is where the standard asks you to prove, with data, that what leaves your site is what your specification and your label claim it is.

Inspection and Laboratory Testing

The expectation is a risk-based testing schedule per product or product group, drawing on your risk assessments, legal requirements in the markets of supply, and customer requirements, with defined methods, frequencies and limits, competent people, and results reviewed and acted on. Where testing underpins safety or legality, the laboratory, internal or external, needs recognised accreditation or operation to ISO/IEC 17025 principles, with justification where accredited methods are not used. Three findings dominate this territory. The schedule that does not connect to the risk assessment, testing what is cheap rather than what matters. The results file with out-of-specification entries and no recorded action, which is worse than not testing because it documents that you knew. And the third-party test report nobody on site can interpret: if you commission testing, someone must own understanding it, and the requirement, including the standard and version to test against, should be formally agreed with the lab rather than left to their assumption.

Quantity Control

Where product is sold by quantity, the control system must meet the legal requirements of the country of supply, average weight or minimum systems as applicable, with records. The trap for exporters is assuming home-market rules travel: they do not, and quantity legislation in the destination market is your problem, not your distributor’s.

Product Sample Control

Where legally required or customer-specified, approved and reference samples must be retained under a defined procedure: identified, stored to preserve condition, retained for a justified period, with controlled access and documented removal. The audit test is simple and physical: the auditor picks a product, asks for the retained sample, and watches how long it takes to find and what state it is in. A melted, mislabelled sample cupboard undoes a beautiful procedure in seconds.

What Changes Under Issue 5

Issue 5, as per the public draft, folds this section into a combined product and process control section, elevates product inspection and testing to Fundamental status, and adds product vulnerability requirements alongside, my product defence and vulnerability piece covers that discipline, and the Issue 5 breakdown has the rest. Back to the series hub, or on to Section 6 part 1.