Product Label Claims

Titan7Lee

Registered
Good day Forum experts.

Is it possible for a multiple ingredient product to have a label claim based on the manufacturing site's certification (Example ISO 9001:2015)?

The manufacturing site is ISO9001:2015 certified and purchases multiple raw materials from multiple sources (strictly based on GMP, ISO, BRC, FSA certification)
Then packages these into a final product based on a specific formulation for the customer. Can this customer make a label claim of ISO 9001:2015?

Kind regards
 
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Grok’s reply:

ISO/IEC 17021-1:2015, which outlines requirements for bodies providing audit and certification of management systems, addresses the use of certification marks, including references to certifications like ISO 9001, in clause 8.4. Specifically, clause 8.4.1 states that a certification body shall have a policy governing the use of any mark it authorizes certified clients to use. This policy must ensure traceability back to the certification body and avoid ambiguity about what has been certified and by whom. Critically, it stipulates that the certification mark “shall not be used on a product or product packaging seen by the consumer or in any other way that may be interpreted as denoting product conformity.”


This means that ISO 9001 certification marks (or references to ISO 9001 certification) are prohibited from appearing on product labels or packaging in a way that could imply the product itself is certified, as ISO 9001 certifies a quality management system, not the product. The restriction aims to prevent consumer confusion, ensuring the certification is understood to apply to the organization’s processes, not the product’s quality or conformity. Companies can, however, use the certification mark in promotional materials, such as brochures or websites, provided they clarify that it pertains to their management system.


For example, a company could state on its website, “Our quality management system is certified to ISO 9001:2015,” but placing “ISO 9001 Certified” on a product label would violate the standard unless accompanied by clear wording that avoids implying product certification, which is rarely practical on labels due to space constraints. Enforcement of this rule varies, and some organizations have been known to skirt it by using generic “ISO 9001 certified” logos, though this risks non-conformance if audited by an accredited certification body.
 
Grok’s reply:

ISO/IEC 17021-1:2015, which outlines requirements for bodies providing audit and certification of management systems, addresses the use of certification marks, including references to certifications like ISO 9001, in clause 8.4. Specifically, clause 8.4.1 states that a certification body shall have a policy governing the use of any mark it authorizes certified clients to use. This policy must ensure traceability back to the certification body and avoid ambiguity about what has been certified and by whom. Critically, it stipulates that the certification mark “shall not be used on a product or product packaging seen by the consumer or in any other way that may be interpreted as denoting product conformity.”


This means that ISO 9001 certification marks (or references to ISO 9001 certification) are prohibited from appearing on product labels or packaging in a way that could imply the product itself is certified, as ISO 9001 certifies a quality management system, not the product. The restriction aims to prevent consumer confusion, ensuring the certification is understood to apply to the organization’s processes, not the product’s quality or conformity. Companies can, however, use the certification mark in promotional materials, such as brochures or websites, provided they clarify that it pertains to their management system.


For example, a company could state on its website, “Our quality management system is certified to ISO 9001:2015,” but placing “ISO 9001 Certified” on a product label would violate the standard unless accompanied by clear wording that avoids implying product certification, which is rarely practical on labels due to space constraints. Enforcement of this rule varies, and some organizations have been known to skirt it by using generic “ISO 9001 certified” logos, though this risks non-conformance if audited by an accredited certification body.
Thank you, this makes sense! I can understand a claim for Kosher and Halal on a product especially when there are many ingredients involved which is done through the relevant body. thank you for the clarity
 
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