BRC Packaging Materials Certification for Printing Plants: 3 Blind Spots in Real Audits—What Auditors Check First Upon Entering the Workshop Is Not the Records, but the Trash Bins

Why I wrote this article

On November 19, 2025, we accompanied an on-site audit at a printing plant in Wuxi that produces export cartons. The plant handles annual orders worth 50 million, mainly supplying Unilever and Beiersdorf. It passed its first BRC Issue 5 audit in 2024 and was preparing for its Issue 6 reassessment in November 2025. At 9 a.m., the auditor sat down in the meeting room without reviewing its procedural documents or organizational chart and said, “I’d like to walk around the workshop first.” He then did something—opened the plastic waste bin in the southeast corner of the workshop, rummaged through it for 3 minutes, and pulled out a rag with ink residue on it.

These three blind spots led the auditor to find 5 nonconformities. The factory could have received an AA rating but ultimately received an A rating. The issues stemmed from 3 blind spots: “on-site 5S + hazardous waste classification + product safety culture.” This article breaks down the 3 blind spots that printing plants are most likely to encounter during a real BRC Packaging Materials Version 6 audit. Each category includes specific scenarios, the questions auditors may ask, and how printing plants should respond. If you are preparing for a BRC audit or have failed a re-audit, this article will be more useful than reading through the BRC standards PDF.

Blind Spot 1: Workshop 5S does not mean “looking clean”; it means “no product residue in the trash bins”

The requirements of BRC Issue 6 for workshop hygiene do not concern “walls and floors,” but the “waste-handling chain.” An auditor’s standard procedure is: upon entering the workshop, first open 3 waste bins—one each in the printing workshop, the die-cutting workshop, and the finished-products workshop.

The logic behind the standard action is: if any one of the 4 categories—"finished products/semi-finished products/raw materials/ink rags"—is found in the trash can, it is deemed a "product safety risk point not identified." The corresponding clauses are 4.3.1 (product handling) and 4.5.1 (cleaning and sanitation). After ink rags were uncovered here in November 2025, the auditor asked 4 questions based on the rags:

1) Which machine does this cloth belong to?
2) What brand of ink is on the cloth?
3) How long has the cloth been in use?
4) Was the cloth weighed and registered before being thrown into the trash?

The printing plant’s workshop director answered the first 3 questions but was unable to answer the 4th: the printing plant actually uses ordinary plastic bags for soiled wiping rags and does not classify them as hazardous waste (ink-contaminated wiping rags fall under HW12 hazardous waste). The auditor immediately raised a “major” finding on the grounds that “the evidence chain for hazardous waste classification has been broken, and the product safety risk assessment has become invalid.”

The printing plant spent 80,000 yuan on subsequent rectification, mainly to install 3 orange hazardous-waste bins in the workshops (1 for printing, 1 for die cutting, and 1 for post-press processing), purchase hazardous-waste registration logs with QR codes, and have employees sign the hazardous-waste record sheet daily to confirm entries. An 80,000-yuan cost is far more worthwhile than a single failed BRC recertification audit (40,000 yuan in external audit fees + the impact of the customer factory audit on orders of 2 million yuan or more).

If you are a printing plant owner, the first thing you should do is change the 3 types of waste bins in the workshop into 5 types—one for ordinary paper scraps, one for raw material packaging, one for hazardous waste (including ink-stained rags/solvent-stained rags/waste liquid), one for finished-product rejects (print failures/die-cutting failures/forming failures), and one for other waste. The bins opened by the auditor will definitely be hazardous waste bins, because hazardous waste is the category most prone to problems. The bin colors should follow GB 18584: blue for general solid waste, orange for hazardous waste, and green for recyclables. This is the color combination that is easiest on an auditor’s eyes.

Blind Spot 2: The document chain should enable traceability from raw materials to finished products within 5 minutes, rather than merely having a complete ledger.

Clause 3.5.1 of BRC Version 6 explicitly requires that "raw materials shall be traceable to the supplier and place of origin, and finished products shall be traceable to the raw materials from the same batch." ISO 9001 permits traceability "where necessary," whereas BRC Version 6 requires that materials be traceable "within 5 minutes under any circumstances"—meaning that the printer’s raw material procurement records, production material input records, finished product inventory records, and batch number association table must form a closed loop.

The closed-loop system of this printing plant looks like this:

When white cardboard is received and put into storage, the warehouse records the batch number L20251020-007. When it is issued to production, the machine operator enters the batch number on the "Material Issue Record" and uploads it to the ERP system. After printing is completed, the die-cutting operator copies this batch number onto the "Process Transfer Form." When the finished products are received into storage, the batch number is linked to the finished goods inventory table. For any product on any order, it is possible to trace forward to determine "which batch of paper was used for this batch of finished products," and trace backward to determine "which finished products were ultimately made from this batch of paper."

The question the auditor asked that day was reversed: “I have selected a batch of finished products. Can you tell me which paper supplier and which production line were used for this batch?” The printing plant retrieved the information in 5 minutes. The auditor then asked: “Was this supplier’s certification ever suspended by the FSC in 2024?” This was where things got difficult: the printing plant needed to check the date on the supplier’s qualification assessment form. If the assessment date preceded the date on which the supplier was suspended, the major criterion would be deemed not satisfied.

The printing factory got through it safely because they completed a supplier annual audit in May 2025, and the assessment date is recorded in the supplier file. The auditor gave the nod. That hurdle was cleared.

In actual practice, the most common mistake print shops make is “failing to carry the batch number forward after die-cutting”—the batch number is still recorded at the printing stage but is omitted after die-cutting, so the trace is broken when the finished products are warehoused. The corrective action is simple: add a line to the process transfer sheet stating “the die-cutting operator copies the raw material batch number.” Five minutes of training is sufficient. Auditors check whether each process has copied the batch number from the preceding step onto the transfer sheet. If the die-cutting operator does not copy it, the traceability chain is immediately judged to be broken.

Blind Spot 3: Product safety culture is not “posted on the wall” but “something employees can answer questions about”

Version 6 of BRC adds a new clause 1.1.4, “Product Safety Culture,” requiring printing plants to establish a mechanism for “top-down communication and bottom-up feedback.” An auditor’s inspection method is to randomly select 3 frontline employees on the shop floor and ask them 3 types of questions:

1) Do you know who customer complaints should be reported to?
2) When did you last attend product safety training?
3) What would you do if you identified a food safety risk in the workshop (for example, ink splashing onto a semi-finished product)?

Employees can answer: Product safety culture is pervasive. Employees cannot answer: Version 6 does not pass, because product safety culture is the dividing line between AA-rated and A-rated products.

During the printing company’s November 2025 audit, the auditor selected a 22-year-old die-cutting worker for an interview and asked, “What would you do if you saw ink splattered on a finished product that was about to be discarded?” The worker replied, “I’d wipe it off with a tissue and put it back on the finished-product stack”—an incorrect answer. The auditor recorded a minor finding on the spot, on the grounds that “the employee did not clearly understand how to handle contaminated products, and the company had not adequately embedded a product safety culture.” The printing company was ultimately not awarded AA, but only A. The 1-point deduction came from this finding.

Product safety culture may sound abstract, but in practice it comes down to 3 concrete actions:

These 3 tasks cost almost nothing, but employees genuinely know them. When the auditor randomly selects employees to interview in the workshop, they speak about specific matters at this factory, not empty platitudes such as “following the procedures as required.” This is where the difference between AA and A lies.

See all 5 failed items from the complete audit

The printing facility has 5 nonconformities: 1) broken chain of evidence for hazardous waste classification implementation (major item), 2) insufficient penetration of product safety culture (major item), 3) missing transfer records for raw material batch numbers after the die-cutting process (minor item), 4) handwashing facilities without a "touchless" faucet (minor item), and 5) customer complaint classification labels not affixed (minor item). 3 minor items + 2 major items = fails AA, passes A.

Remediation took 4 weeks, evidence was submitted in week 6, and the review was passed 28 days later, resulting in an A-level certificate. A-level certificates are accepted by default by European and Southeast Asian customers and are sufficient for B2B bids from major customers. Not obtaining AA certification in this round is a minor issue because 90% of this printing company’s customers only require A-level certification. However, if the company aims to position itself as an AA-level supplier for high-end food exports, targeting customers such as Ferrero or Mondelez, AA certification is a prerequisite, and failing just 1 major item is enough to disqualify it from bidding.

Further reading