BRCGS standards: your practical questions answered
Pet food, outsourced storage, notifying your CB, who owns the report, interpretation, common NCs, CAPA effectiveness and free BRCGS resources.
A round-up of the practical BRCGS questions our community has asked, answered by our lead auditors and BRCGS Approved Training Partners.
Q: Does a pet food manufacturer need to meet the whole BRCGS Food Standard?
Yes, the whole standard applies. Some things differ: allergens aren't the legislated human list; instead, manufacturers make "free from" claims for allergens common in pets, such as chicken or salmon. Microbiological risk is generally lower for dogs than for people, so for long-life products like canned food the focus is more on toxins and spoilage. Some speciality pet foods are medicated and prescription-only, and the Food Standard covers medicinal pet foods (clause 5.8.3).
Q: We're storing finished product at an external warehouse. Is that outsourcing?
It can be. BRCGS Food Issue 9 (3.5.4) defines outsourced processing as an intermediate step, including storage, completed at another company or site, with the product then returning to the audited site. So if the warehouse is a separate contracted business and the product comes back to your site before going to customers, it counts as outsourced processing, even for finished product.
Q: Our technical manager has left. Must we tell the certification body?
Not if an interim technical manager and/or quality manager are covering all the responsibilities and there's no impact on compliance or food safety. Significant staff changes – absolutely, mention this to your CB.
Q: Who decides who sees our audit report and certificate?
The company that commissions the audit. The report belongs to you and can't be shared without your permission unless required by law. You can share it with customers through the BRCGS Directory. Certification bodies must upload reports to the Directory within set timelines. This is set out in the audit protocol (Part III of BRCGS Food Safety Issue 9), and the same principle applies across the BRCGS Standards. You control sharing in the BRCGS Directory and can remove it at any time.
Q: Is the standard open to interpretation?
Some. It has to be flexible enough to fit very different operations, with clauses applied "as appropriate" and "based on risk". On auditor courses, groups given the same NC scenario often reach very different answers. Document how you apply each requirement so you're consistent and transparent. BRCGS explains the intent of each clause in the Issue 9 Interpretation Guideline, available from the BRCGS Store; its Issue 9 position statements (document F926) clarify specific points. We discuss different interpretations on our BRCGS courses.
Q: What are the most common Issue 9 non-conformities?
Mostly the same as Issue 8: cleaning of equipment and premises (4.11.1), chemical storage and handling (4.9.1.1), equipment design and construction (4.6.2), and the condition of doors (4.4.8) and walls (4.4.1). Clause 4.6.2 changed significantly in Issue 9. One NC our trainers raise often: no scope for each internal audit (3.4.1). BRCGS publishes its top non-conformities every year in its annual report and data releases, and they differ between Standards: the hygiene clause is 4.8 in Packaging Issue 7 and 6.4 in Storage & Distribution Issue 4. We cover common non-conformities on our BRCGS courses.
Q: Does BRCGS certification reduce customer audits?
If you supply other businesses, it significantly reduces the burden and the information you need to provide. Retailers often still audit, and some won't talk to you without GFSI certification. Even where it doesn't reduce audits, a BRCGS audit picks up issues before your customer does. Some sites still host 20–30 audits a year, so audit fatigue is real, but staff who are used to audits treat them as just another day. Many customers accept it because BRCGS Food Safety is benchmarked by GFSI.
Q: What's often missed in CAPA records?
Every BRCGS Standard requires verification that the correction is implemented and effective (each has an equivalent corrective and preventive action clause). Many CAPA logs show the action completed and verified, with no evidence it actually prevented recurrence. Add "Effectiveness verified: Yes/No" with a date and a short comment or evidence.
Q: Gluten-Free Issue 4: did graded NCs help?
Our trainers think so. Issue 3 referred to NC severity and NC numbers affecting certification without defining them. Issue 4 aligned the protocol with the rest of the BRCGS suite, giving clearer severity grading and a clear pass/fail threshold. Critical, major and minor grading is used across the BRCGS Standards.
Q: Do I need a HACCP certificate to sell on Amazon?
People often confuse an individual's HACCP training certificate with a business being certificated to HACCP. They're completely different. See our HACCP Certification service.
▶ Watch: HACCP certification to sell on Amazon (STC & QTC Explains)
Q: Where can I find BRCGS standards and guides for free?
You can download the standards free from www.brcgs.com, which is essential (if you haven't already) before attending a BRCGS course. Staff at certificated sites can get a free account on BRCGS Participate to download guides, such as the pest management best practice guide. BRCGS also publishes position statements for each GFSI-benchmarked standard; check for them regularly, as awareness of them is a requirement of the BRCGS Standards. For a newly published standard, BRCGS's Guide to Key Changes helps a lot too.
More short videos on our STC & QTC Explains channel: https://youtube.com/@stcandqtc
Reviewed by Cathy Gladwin, Director & BRCGS ATP Trainer, STC · November 2026
These Q&As share general best practice from our trainers and auditors. They aren't consultancy advice for your site. For support specific to your site and systems, we can refer you to our sister company QTC.
Learn more: see all BRCGS courses on the course calendar. For certification support, contact STC.