BRCGS has published updated position statements for four of its Global Standards, effective for all audits conducted from 10 August 2026.
The changes bring Food Safety Issue 9, Packaging Materials Issue 7, Storage and Distribution Issue 4, and Agents and Brokers Issue 3 into alignment with the Global Food Safety Initiative (GFSI) Benchmarking Requirements version 2024. Certificated sites should review the relevant updates now and ensure compliance is in place before the effective date.
What is changing and why
GFSI periodically updates its benchmarking requirements to reflect evolving food safety science, regulatory expectations and industry best practice. Where BRCGS standards are benchmarked against GFSI, they must demonstrate compliance with those requirements; these position statements represent the formal mechanism by which BRCGS introduces the necessary clause-level changes ahead of a full standard revision.
The updates span areas including prerequisite programme management, food defence and threat assessment, vulnerability assessments for product fraud, personnel responsibilities and, in the case of Food Safety, protective clothing requirements. Several of the changes introduce new competency expectations for the teams responsible for threat and vulnerability assessments, requiring demonstrable knowledge of the relevant risks and principles rather than simply having a procedure in place.
Food Safety Issue 9
The sole new clause change in this update concerns protective clothing (clause 7.4.2). The amendment adds an explicit requirement for suitable protective footwear where required to prevent product contamination, alongside the existing requirement for snoods for beards and moustaches. Whilst many sites will already provide appropriate footwear as a matter of practice, the clause now formalises this as a specific auditable requirement. Sites should review their current protective clothing policy and ensure that footwear requirements are risk-assessed, documented and consistently applied.
The three existing position statements covering audit protocol (site responsibility for unannounced audits, certification body changes and the definition of initial audits) have received minor wording amendments in this version; the intent of those statements has not changed.
Effective date: 10 August 2026
Packaging Materials Issue 7
This is the first position statement document published for Packaging Materials Issue 7, and it introduces changes to two clauses. For site security and product defence (clause 4.4.1), the update adds an explicit requirement that personnel engaged in threat assessments and product defence plans must be appropriately trained, with a direct cross-reference to the training requirements in clause 6.1. For housekeeping and cleaning (clause 4.8.2), the changes introduce disinfection as a consideration alongside cleaning, require that cleaning procedures are validated and verified based on the risks of the intended product use or activity, and add a formal definition of disinfection to the standard's glossary.
Sites should review their threat assessment teams to confirm that competency is documented and traceable to the training clause. Cleaning schedules and procedures should be reviewed to determine whether validation and verification records are in place, particularly where the nature of the product or process presents a higher risk profile.
Effective date: 10 August 2026
Storage and Distribution Issue 4
This version of the position statements document (version 8) introduces nine new position statements alongside minor wording amendments to several existing ones. The new changes, all driven by GFSI BMR 2024 alignment, cover the following areas.
Personnel roles and responsibilities (clause 1.3.2) now requires that staff demonstrate their work is carried out in accordance with documented site policies, procedures, work instructions and existing practices, with all personnel having access to relevant documentation. Prerequisite programmes (clause 2.1) have been strengthened to require that control measures and monitoring procedures are clearly documented and verified where appropriate, and that prerequisite programme information is explicitly incorporated into the development and review of the Hazard Analysis and Risk Assessment (HARA) or Hazard Analysis and Critical Control Point (HACCP) plan.
For supplier and subcontractor management (clauses 3.5.1.2 and 3.5.2.1), specifications and contracts must now explicitly include chemical, microbiological, physical or allergen standards where relevant to safe handling, and subcontractor agreements must be signed by both parties. The vulnerability assessment clause (3.5.3.1) introduces the same competency expectation seen elsewhere: the individual or team responsible must understand the principles of vulnerability assessment and the risks associated with the products, supply chain or processes being assessed.
The security risk assessment clause (4.2.1) now requires that threat assessment personnel understand the principles of product defence and the products being stored and distributed, with any legally required training to be demonstrably completed. The equipment clause (6.1) has been amended to include storage of equipment within its scope, requiring that equipment is stored so as not to become a contamination source. Cleaning requirements (clause 6.4.5) now specify that cleaning equipment must be hygienically designed, suitably identified (for example by colour-coding) and cleaned and stored hygienically.
Section 17, covering contract operations such as chilling, freezing and tempering, has been updated to include irradiation within its scope; the clause title and statement of intent have both been amended accordingly. The associated process monitoring clause (17.3) now includes irradiation among the process parameters to be monitored.
Effective date: 10 August 2026 (for new clauses; existing position statements retain their original effective dates)
Agents and Brokers Issue 3
Four new position statements have been added, all effective from 10 August 2026. The risk analysis clause (2.7) has been updated to require that appropriate prerequisite programmes are in place before a risk analysis is conducted, that control measures and monitoring procedures forming part of those programmes are documented and verified where appropriate, and that prerequisite programme information is taken into account when developing and reviewing the plan. The interpretation guidance accompanying this clause makes clear that prerequisite programmes form the foundation of the HARA or HACCP plan, and that each identified prerequisite requires a structured workstream to ensure it delivers the intended level of control.
Product specifications (clause 3.6.1) now require that specifications include chemical, microbiological, physical or allergen standards where relevant to safe product use; the interpretation guidance confirms that specifications must cover ingredients (including allergens), nutritional information, preparation or cooking instructions, storage instructions, shelf life and quantity as a minimum.
The threat assessment clause (4.3.1) and vulnerability assessment clause (4.8.2) both introduce the same competency requirements seen across the other standards: personnel engaged in these activities must understand the relevant risks and principles, with any legally required training to be in place.
Effective date: 10 August 2026
What certificated organisations need to do
Organisations certified to any of these four standards should take the following steps ahead of the August 2026 deadline.
Review the relevant updated position statement in full, available on the BRCGS website. Conduct a gap assessment against the new or amended clauses, paying particular attention to competency requirements for threat assessment and vulnerability assessment teams, as these represent a substantive shift in expectation across multiple standards. Ensure that prerequisite programme documentation, verification records and their linkage to the HARA or HACCP plan are reviewed and updated where necessary. Update relevant procedures, training records and internal audit programmes to reflect the changes, and confirm that the effective date is built into your audit preparation timeline.
Audits conducted from 10 August 2026 will be assessed against these updated requirements.
Speak to our BRCGS experts
Have questions about how these updates apply to your certification? Our team works with organisations across all four standards and can help you understand what the changes mean in practice for your site, scope and operations.
