Hi Martyn,
I'm not entirely sure whether yr ultimate query referred to 3.9.1 or 3.9.2 ? Or both ? (3.9.1 also has the "relevant" packaging "bonus")
Textually BRC seem to (scope) distinguish between “identification” in 3.9.1 and “testing” in 3.9.2. Such a distinction, if any, seems rather illogical IMO.
From the glossary –
Primary packaging - That packaging which constitutes the unit of sale, used and disposed of by the consumer (e.g. bottle, closure and label).
Secondary packaging - Packaging that is used to collate and transport sales units to the retail environment (e.g. corrugated case)
Assuming glossary is accurate, if the outer carton you refer to is classified as secondary the answer is apparently No.
However, from a risk assessment POV, primary packaging is also definable as packaging which is potentially in food contact. This could expand the scope as compared to above definition.
From above threads, it is unclear to me how auditors have been interpreting “primary” in the context of 3.9.2.
Also see these 2 related threads which may overall clarify the topic a little –
http://www.ifsqn.com...93-cases-totes/
http://www.ifsqn.com...1-traceability/
For BRC6 (where .1 and .2 were very similar to BRC7), BRC offered a "Traceability Introduction" including a sort of model example which, vaguely, "implies" all packaging is potentially relevant, see -
http://www.ifsqn.com...ge-3#entry93246
It may all come down to the actual packaging style, ie Primary = ?