BRCGS Issue 9: Clear Guide to 328 Clauses and 4 Updates

BRCGS Issue 9 is the current edition of the BRCGS Global Standard for Food Safety. The Appendix 7 certificate template dates the issue August 2022, and Part I sets the start of certification at 1 February 2023. Audits before that date stayed on Issue 8 for the life of their certificates. Everything since then has been against Issue 9, amended by position statements.

This post walks through the structure, the changes made since publication and what to check if you are still working from a 2022 copy. It is independent of BRCGS. For the Standard itself, including the free PDF BRCGS lists, go to brcgs.com. Our overview of the whole scheme is in BRCGS certification.

How BRCGS Issue 9 is built

Issue 9 has three parts. Part I explains the scheme. Part II holds the requirements. Part III is the audit protocol. Part II runs to 9 sections, 72 subsections and 328 clauses that carry a requirement. It also carries 57 statements of intent, which are audited in their own right.

The section sizes show where the weight sits. Site standards is the biggest by a distance.

Sections 1 to 7 apply to every site, apart from clauses 5.8 and 5.9, which depend on your products. Section 8 applies if your risk zone assessment finds that you need any of the three kinds of controlled zone. Section 9 applies if you bring traded products into scope. Clauses 5.8 (pet food and animal feed) and 5.9 (animal primary conversion) apply only where the site does that work.

What BRCGS Issue 9 asks of senior management

Section 1 is short but it sets the tone, and clause 1.1 is one of the twelve fundamentals. Issue 9 expects a food safety and quality culture plan, not just a policy. It must contain activities, an action plan and a review of whether the plan worked. The plan is reviewed annually, objective results go to senior management and all staff each quarter, and management review happens annually with a meeting programme to senior management each month.

A senior manager must also be available for a culture discussion during the audit (clause 1.1.11). Plan for it. Our post on food safety culture covers the topic beyond this Standard.

The main requirements of BRCGS Issue 9, section by section

Section 2, the food safety plan. It is fundamental. It rests on the Codex HACCP principles, and the flow diagram is verified on site annually and at process change. The plan and prerequisite programmes are reviewed annually and before relevant change. See HACCP principles if the basics need refreshing.

Section 3, the management system. It covers documentation, internal audit, supplier approval, specifications, corrective action, traceability, complaints and incident management. Several clauses demand more than their title. Internal audit has two separate tests: at least four dates spread over the year, and every system activity audited once a year. Hygiene and fabrication inspections in open product areas are a second programme, monthly, and they do not count as internal audit.

Section 4, site standards. At 125 clauses, this is where audits are won and lost on the floor. It runs from external standards and security to layout, building fabric, utilities, equipment, maintenance, staff facilities, chemical and physical contamination control, foreign body detection, housekeeping, waste, pest control, storage and transport. Clause 4.3 on layout and flow and clause 4.11 on housekeeping and cleaning are fundamental.

Section 5, product control. It covers product design, shelf life, allergen management, authenticity and fraud, packaging and testing. Allergen management (5.3) is fundamental.

Section 6, process control. It covers specifications and work instructions, labelling and pack control, quantity control and calibration. Clauses 6.1 and 6.2 are fundamental.

Section 7, personnel. Training (7.1) is fundamental. The section also covers personal hygiene, medical screening and protective clothing.

Sections 8 and 9. These are the conditional ones, covered under risk zones and traded products.

Twelve requirement groups carry the fundamental label across these sections. The list and their evidence are in BRCGS fundamental clauses.

The F926 position statements that amend BRCGS Issue 9

BRCGS publishes position statements under reference F926. They are binding as an extension of the Standard, and they apply from the date stated, or from publication on the website if no date is given. The current version is 5, dated 6 October 2026, which was a rebranding only. Version 4 (27 April 2026, effective 10 August 2026) made small wording changes, aligned the text with the GFSI Benchmarking Requirements v.2024 and added the fourth statement.

PS1 makes the site responsible for being ready for an unannounced audit, and for putting contract arrangements in place before the four-month window opens. Late arrangements move the due date, the audit falls in the following four months, a major is raised and the certificate may expire. It replaces the printed text of Part III 4.7.1, so use the statement.

PS2 bars a change of certification body in the last four months before the due date, unless BRCGS agrees in writing.

PS3 narrows the initial audit to the first audit at an address, or an audit after a certificate has lapsed for over 24 months. A site lapsed for less than that is not an initial audit under PS3. It is still not eligible for blended, because Part III separately bars blended for a site with no current certificate.

PS4 adds footwear to the protective clothing list in clause 7.4.2, where needed, and the interpretation says appropriate footwear must be issued and worn. Write the stronger reading into your procedures. The footwear rules in section 8 still apply on top for risk zones.

Where a 2022 copy of BRCGS Issue 9 now misleads you

If you hold the original print or a downloaded copy, check these points:

• Clause 1.1.10 stops at the audit due date in the printed text. PS1 adds the readiness duty.
• Part III 4.7.1 puts the unannounced window on the certification body in the printed text. PS1 replaces it.
• Clause 7.4.2 has no footwear in print. PS4 adds it.
• The printed definition of an initial audit covers any site without a valid certificate. PS3 narrows it.

The Standard also contains a few internal inconsistencies, such as which event the three-month clocks count from. Our working position is to count from the last audit, as Part III 2.1.1, 2.1.3 and PS1 do. If a point matters to your certificate, confirm it with your certification body.

What the BRCGS Issue 9 statements of intent mean for you

A statement of intent is the short purpose statement that heads a group of clauses. Issue 9 counts 57 of them and audits them in their own right. Sections 2 and 8 have one at section level and none on their subsections. Clause 3.5 has none itself, but 3.5.1 to 3.5.4 each have one. Section 9 opens with scope rules and has its statements on 9.1 to 9.6.

The practical point is that a site can meet most clauses in a group and still be found not to meet the purpose. When you assess yourself, ask the intent question first, then the clause questions.

What is changing next after BRCGS Issue 9

BRCGS has an Issue 10 in development. We know of no publication date, start of certification or transition period, and we will not guess one. F926 version 5 still applies to Issue 9. Work to Issue 9 now, and check the BRCGS website for announcements.

Moving a site onto BRCGS Issue 9

A site that held Issue 8 should do a clause-by-clause gap check against Issue 9 rather than assume the old system carries across. A site new to BRCGS can start with section 2, then work outward.

1. Obtain Issue 9 and the current position statements.
2. Score every clause: met, partly met or not met.
3. Mark the fundamentals and fix those gaps first.
4. Check the conditional sections against your site and record the decisions.
5. Update procedures for PS1 and PS4.

The method is set out in BRCGS audit checklist. For the route to a certificate, return to BRCGS certification.

The BRCGS Food Safety Toolkit has 123 templates, 78 in Word and 45 in Excel, for $149, written for Issue 9 and the current position statements. Start with the Issue 9 Self-Assessment and Implementation Roadmap, the Legislation, Registrations and Position Statement Register and the Certification Scope and Exclusions Record.

Sample pages from the toolkit: Issue 9 self assessment; Food safety and quality culture plan; Food defence plan.

BRCGS Issue 9 FAQ

Is BRCGS Issue 9 still current?

Yes. Issue 9 is current, and the position statements, version 5 of 6 October 2026, still apply to it.

When is Issue 10 coming?

We do not know. BRCGS has not given a date that we can verify, so we do not state one.

How many clauses does BRCGS Issue 9 have?

Part II has 328 clauses carrying a requirement, in 9 sections and 72 subsections, plus 57 statements of intent.

Do the position statements change the audit?

They amend the printed text and bind like the Standard. The four statements cover unannounced audit readiness, changing certification body, the initial audit definition and footwear.

Do I need a new system if I was audited to Issue 8?

Not a new one, but you need a gap check. Read the requirements against what you actually do.