BRCGS Position Statement Updates: What UK Certificated Sites Need to Know

BRCGS has released a new round of amendments to several Position Statements, affecting Agents & Brokers (AB310), Food Safety (F926), Storage & Distribution (SD404) and Global Standard Packaging Materials, Issue 7 (P708).

The changes align the affected standards with the GFSI Benchmarking Requirements (BMR) 2024 and took effect on 10 August 2026.

For organisations certificated to these standards, the changes are relevant not only to documented procedures but also to how risk assessments, competence, supplier controls, product defence and operational controls are implemented and evidenced.

Certification bodies can assess sites against the applicable Position Statement requirements from the effective date. UK businesses should therefore ensure that their management systems, personnel and supporting records reflect the updated requirements.

What Has Changed?

The updates cover several areas, but a common theme is emerging: BRCGS is placing greater emphasis on demonstrable competence, risk-based decision-making and effective implementation, rather than relying solely on documented procedures.

The key changes are outlined below.

Agents & Brokers – AB310

Four clauses have received significant clarification.

Clause 2.7.1 – Prerequisite Programmes and Risk Analysis

Prerequisite programmes must be established before hazard and risk analysis is undertaken. Existing controls provided through these programmes should be documented and taken into account as part of the risk analysis.

For UK organisations, this reinforces the need to demonstrate a logical relationship between prerequisite programmes, hazard analysis and the controls identified within the management system.

Clause 3.6.1 – Product Specifications

The definition of key data within product specifications has been strengthened. Specifications should address relevant chemical, microbiological, physical and allergen parameters, with the information supported by applicable legislation or sound scientific evidence.

Sites should review whether their specifications contain sufficient information and whether the basis for specified limits and requirements can be demonstrated.

Clause 4.3.1 – Product Defence

Personnel undertaking product defence assessments are expected to have appropriate competence.

This means organisations should be able to demonstrate more than simply having a completed assessment. Training, experience, qualifications or other evidence of competence may need to support the personnel responsible for undertaking the assessment.

Clause 4.8.2 – Vulnerability Assessments

A similar emphasis on competence applies to vulnerability assessments relating to food fraud.

Organisations should consider whether the personnel conducting these assessments have appropriate knowledge of areas such as purchasing, technical controls, supply chains and food fraud risks.

Food Safety – F926

Clause 7.4.2 – Protective Clothing

The update provides greater clarity around protective clothing and personal protective equipment.

Requirements now explicitly address snoods for facial hair and suitable protective footwear where necessary.

UK food businesses should review their existing protective clothing procedures and consider whether the controls remain appropriate for different areas, activities and product risks.

This should also be considered alongside the organisation’s existing hygiene procedures, HACCP-based controls and applicable UK food hygiene requirements.

Storage & Distribution – SD404

SD404 contains the broadest range of changes in this update.

Clause 3.5.1.2 – Supplier Specifications

Supplier specifications should include relevant chemical, microbiological, physical and allergen parameters.

This brings the expectations more closely into line with the changes introduced for Agents & Brokers.

Clause 3.5.2.1 – Subcontractor Agreements

Subcontractor agreements must clearly define relevant product-handling conditions and safety parameters.

Where activities are outsourced, organisations should ensure that contractual arrangements provide sufficient control over the activities that may affect product safety, quality or legality.

This is particularly relevant to UK operators using third-party storage, transport, processing or other outsourced services.

Clauses 3.5.3.1 and 4.2.1 – Competence and Product Security

The amendments introduce explicit competence expectations for vulnerability assessments and product security/food defence.

Organisations should consider whether the people responsible for these activities have suitable training, knowledge and experience, and whether evidence of competence is maintained.

Clause 6.1 – Equipment

Equipment must be suitable for its intended purpose and stored in a way that minimises contamination risks.

Organisations should also consider the movement of equipment between different areas and whether this could introduce contamination or other product-safety risks.

Clause 6.4.5 – Cleaning Equipment

Cleaning equipment controls have been strengthened, including expectations relating to:

• Hygienic design
• Identification
• Appropriate storage
• Prevention of cross-contamination

Sites should review cleaning equipment arrangements and ensure that controls are implemented consistently across relevant areas.

Section 17 – Contract Processing

The scope of contract processing activities has been expanded to include irradiation, alongside activities such as chilling, freezing, tempering, defrosting and high-pressure processing.

Where irradiation is undertaken as a contract processing activity, the organisation must operate in accordance with the relevant product owner’s specifications.

Clause 17.3 – Process Monitoring

Process monitoring requirements have also been broadened.

Depending on the activity, monitoring may include temperature, pressure and irradiation parameters, together with automatic failure alarms where appropriate.

Organisations undertaking contract processing should therefore review their monitoring systems, alarm arrangements, records and escalation procedures.

Global Standard Packaging Materials, Issue 7 – P708

BRCGS has also introduced a new Position Statement relating to the Global Standard Packaging Materials, Issue 7.

Clause 4.4.1 – Threat Assessments and Product Defence

Personnel involved in threat assessments and product defence plans must have appropriate training and competence, in line with Clause 6.1.

This formalises the expectation that personnel responsible for these activities understand the risks being assessed and are suitably competent to carry out their responsibilities.

Clause 4.8.2 – Cleaning and Disinfection

Two important requirements have been introduced.

Where appropriate, organisations must establish and maintain disinfection procedures alongside cleaning procedures.

Cleaning procedures must also be appropriately validated and verified, taking account of the risk associated with the intended use of the product.

Packaging manufacturers should therefore review cleaning and disinfection programmes and ensure that validation and verification activities are supported by appropriate evidence.

Appendix 8 – Definition of Disinfection

Appendix 8 now includes a formal definition of disinfection, providing greater clarity around terminology used within the standard.

What Should UK Certificated Sites Do Now?

The Position Statement changes should be treated as part of the site’s certification requirements rather than simply as an information update.

UK sites affected by the changes should consider undertaking a documented review of their management system and operational controls.

Areas to review include:

• Risk assessments: Are hazard, vulnerability and threat assessments current and supported by appropriate evidence?
• Competence: Can the organisation demonstrate that personnel undertaking these assessments are suitably trained and competent?
• Specifications: Do product and supplier specifications contain the required chemical, microbiological, physical and allergen information?
• Supplier and subcontractor controls: Do agreements clearly define relevant product-safety requirements?
• Food defence and product security: Are assessments current, effective and supported by competent personnel?
• Cleaning and disinfection: Are procedures appropriate, validated and verified where required?
• Equipment controls: Is equipment suitably designed, identified, stored and controlled to minimise contamination risks?
• Contract processing: Do sites undertaking processing activities covered by Section 17 have appropriate monitoring and control arrangements?
• Records and evidence: Can the organisation demonstrate that its procedures are actually implemented in practice?

UK Regulatory Considerations

BRCGS certification does not replace an organisation’s legal obligations.

UK food businesses must continue to comply with applicable food safety, hygiene, traceability, labelling and other legal requirements relevant to their activities. Depending on the location and activities of the organisation, this may include applicable requirements arising from UK food law, retained legislation and requirements enforced by the relevant competent authorities.

The Position Statement updates should therefore be considered alongside the organisation’s existing HACCP-based food safety management system, legal compliance evaluation, supplier controls and regulatory requirements.

For organisations operating across the UK and EU, additional requirements may also apply depending on the products, markets and activities involved.

Why Competence Is Becoming Increasingly Important

One of the clearest themes across these changes is competence.

BRCGS is increasingly focused on whether people responsible for activities such as vulnerability assessments, product defence and threat assessments actually understand the risks involved.

For certificated sites, this means that training matrices alone may not tell the whole story. Organisations should be able to demonstrate how competence has been established and maintained through appropriate training, qualifications, experience, practical involvement and ongoing evaluation.

This is particularly important where risk assessments are complex or require input from several functions, such as technical, purchasing, supply chain and operations.

Preparing for Your Next BRCGS Audit

The best approach is not to wait until the next scheduled audit to identify gaps.

Sites should review the applicable Position Statements against their existing procedures and records, identify any changes required, assign responsibility and retain evidence that the changes have been implemented.

Particular attention should be given to areas where the Position Statements introduce or clarify expectations around competence, vulnerability assessments, product defence, supplier specifications, subcontractor controls and operational monitoring.

How PJRFSI UK Can Help

At Perry Johnson Registrars Food Safety, Inc. (PJRFSI), we work with organisations seeking and maintaining certification against BRCGS and other recognised food-safety schemes.

Our UK team can help organisations understand how changes to certification requirements may affect their management systems and audit preparation.

Our experience covers BRCGS requirements across areas including:

• Agents & Brokers
• Food Safety
• Storage & Distribution
• Packaging Materials
• Supplier and subcontractor controls
• Food defence and vulnerability assessments
• GFSI-recognised certification schemes

Final Thoughts

The latest BRCGS Position Statement updates reinforce a broader direction within food-safety certification: organisations are expected to demonstrate that their systems are risk-based, implemented effectively and supported by competent personnel.

For UK certificated sites, the priority should now be to review the applicable Position Statements, assess any gaps and ensure that changes have been implemented and can be demonstrated through appropriate records and objective evidence.

If you are unsure how the changes affect your BRCGS certification, contact PJRFSI UK to discuss your requirements and prepare for your next certification audit.