It is impossible to ignore the new standard, which has already changed several times in the last decade and must be followed by food suppliers exporting their goods from India to the UK, Europe, and other countries demanding BRCGS certification. The new BRCGS Issue 9 has been mandatory since 1 February 2023 and was used as the foundation of all audits that took place after that. It seems extremely unlikely that all facilities working under the previous standard version will comply with the new one. In this paper, we will talk about BRCGS Issue 9 and Issue 8 and note some changes of the standard that have occurred and affect Indian manufacturers who want to get BRCGS certification.
BRCGS certification has already become the regular process for Indian food suppliers exporting their products such as snacks, ready-meals, spices, and seafood to the UK and the European Union. Nevertheless, the certification process under the previous version of the standard may cause some troubles during the audit and approval procedures. Knowing the fact that the standard has become more strict is not enough – it is important to know about the differences between these two versions.
BRCGS Issue 9 vs Issue 8: An Overview
The Global Standard for Food Safety is provided by BRCGS (Brand Reputation through Compliance Global Standards). It is one of the most well-known GFSI benchmarking standards accepted by the major retailers and food service providers worldwide. The BRCGS Issue 8 Standards started working on 1 August 2018 and were the basis for certification during almost four years. The BRCGS Issue 9 Requirements were released on 1 August 2022, however, there was a transitional period until the mandatory standard became effective.
The differences between the BRCGS Issue 9 and Issue 8 Requirements are quite significant. The BRCGS Issue 9 Requirements were created based on the most common non-conformities found in thousands of audits performed in 2021. Therefore, it can be seen that the Indian exporters to the UK and EU retailers need to demonstrate more dedication from the management side, the implementation of the food safety culture program, and equipment hygiene requirements.
All of the above, nevertheless, share a common conceptual framework which includes fundamental requirements, food safety management system according to the HACCP principle, quality management system, facility requirements, process/product control and personnel. Therefore, one can say that getting certified in eight standards does not mean that the producers will start their work again from zero. Regrettably, the more important issue under the conditions described above would be the quality of evidence provided within the conceptual framework and the number of clauses, where just having the policy is no longer sufficient.
Timeline: From BRCGS Issue 8 Standards to BRCGS Issue 9 Requirements
The transition between the two issues followed a defined timeline that certified sites and applicant sites both had to work around:
| Milestone | Date |
|---|---|
| BRCGS Issue 8 published | 1 August 2018 |
| BRCGS Issue 9 published | 1 August 2022 |
| Issue 9 becomes mandatory for all audits | 1 February 2023 |
| Issue 8 certificates | Allowed to run to natural expiry, no extensions |
An audit which occurs from or after 1st February 2023 will be evaluated based on Issue 9 of BRCGS, irrespective of the time at which the site received its certification. The audits that occurred prior to the specified date were rated once more according to Issue 8. It is not possible now to conduct an audit for certification against Issue 8.
Key Changes in BRCGS Issue 9 vs Issue 8
The following table outlines the key differences between the two sets of standards. These are explained further in the subsequent sections.
| Area | BRCGS Issue 8 | BRCGS Issue 9 |
|---|---|---|
| Food safety culture | Covered under a single clause (1.1.2), largely a policy statement | Runs through multiple sections; requires a documented, measurable culture plan |
| Senior management role | Sign-off on policy expected | Active, demonstrable commitment; representative must be present at audit |
| Audit options | Announced and unannounced audits only | Adds a third option — the blended audit (partly remote, up to 50%) |
| HACCP / food safety plan | Single structure for own-brand and traded products | Restructured; traded products addressed in a distinct new section (9.1) |
| Validation of food safety plans | Not explicitly required before implementation | Mandatory validation before implementation or before any change affecting safety |
| Equipment management | General requirements on suitability and maintenance | Far more detailed clause (4.6.1) covering purchase specification and hygienic design |
Food Safety and Quality Culture
This is the biggest change from BRCGS Issue 8 to BRCGS Issue 9. In BRCGS Issue 8, food safety culture was covered in just one clause. In BRCGS Issue 9, sites are expected to have a document detailing how to develop and improve food safety and quality culture. This includes:
- Specific activities, timeframes, and performance measures
- Evidence of staff feedback processes that are integrated into the plan
- Annual review and revision of the plan – an update frequency not mentioned in Issue 8
- Presence of a senior management representative on-site for discussion of the plan with the auditor
Audit Protocol: The Blended Audit
BRCGS Issue 9 adds a new audit format to the two existing formats: the announced and unannounced audits. The mixed audit is an announced audit that takes place both in-person and online where the certification body determines the extent to which the audit will take place online, which cannot exceed 50 percent of the total audit depending on the technical capability of the facility. This type of audit does not exist in BRCGS Issue 8 Standards.
HACCP and the Food Safety Plan
With Issue 9, a new section 9.1 has been included regarding those products traded with their own HACCP plan or an integrated plan within the site plan placed before sections which were taken from Issue 8. The new issue includes a clause for validation of HACCP or food safety plan either prior to its implementation or prior to making changes to any factor affecting safety of the product.
Equipment and Hygienic Design
Since equipment-based non-conformances were one of the frequently observed cases for Issue 8, BRCGS Issue 9 made it mandatory to include a purchase specification for equipment, greater emphasis on hygienic design at the time of purchasing equipment, and better documentation of maintenance activities. Indian manufacturers who produce any of the above-mentioned product categories can expect this section to be more thoroughly audited in the upcoming audit cycle.
BRCGS Certification Updates: What Indian Food Manufacturers Must Do
Indian exporters certified under the older standard, or preparing for first-time certification, should treat the following as a working checklist for the transition:
- Get hold of the official version of BRCGS Issue 9 and compare each clause with the management system that is currently employed at the site
- Prepare or update the documented Food Safety & Quality Culture plan, specifying the activities, their owners, and the review dates
- Make sure a senior management representative will be accessible during the certification audit
- Ensure that the HACCP and food safety plans are validated before implementation or any change to the process
- Check the equipment procurement process, taking into account its hygienic design and specification
- Determine, in agreement with the certification body, which type of audit would fit the site better
BRCGS further issues clarifications through Position Statements available on their website during the period between the revision of the standards, and it is the duty of the certified organizations to be up-to-date with these clarifications since they are supposed to have an official copy of the standards updated at all times.
As a starter for those organizations that are converting to BRCGS for the first time, it would be more appropriate to buy the BRCGS Guide to Key Changes Issue 9 and interpretation guideline, both from BRCGS, and compare each line of these documents to the existing procedures under Issue 8 of the management system, rather than rewrite the whole management system. According to most Indian companies that have been through the conversion process, the cultural program, senior management availability, and equipment specification sheets are what take most time by the auditor.
It is equally important to state that BRCGS has already begun the process of creating the next edition. A public review for the coming Issue 10 was conducted until February 2026 and a Technical Working Group started meeting from April 2026 onwards. However, formal publication of this document will not be expected until 2027. Until the next version becomes finalized and undergoes its transition phase, the current edition of BRCGS will remain mandatory for auditing and system development.
Is BRCGS Issue 9 Mandatory for Certified Food Manufacturers
Yes. Starting from 1st February 2023, all BRCGS Global Standard for Food Safety audits have been carried out using Issue 9. The use of Issue 8 is not possible anymore, and those companies that have documents, training, or internal audit checklists that still refer to Issue 8 must upgrade to Issue 9 before the next planned or unannounced audit. Purchasers and retailers who are sourcing products from Indian companies will require certificates in respect of Issue 9 only.
Key Takeaways
- Since 1 February 2023, all certification audits require Issue 9 of BRCGS; Issue 8 is no longer applied.
- The most important difference between Issue 9 and Issue 8 of BRCGS lies in the transition from a single culture clause to a measured and documented plan of food safety and quality culture.
- Issue 9 provides a possibility of conducting a combined audit where up to 50 percent of the audit can be conducted remotely.
- HACCP and food safety plans must now be validated prior to their application, and there is a separate section about traded goods.
- Issue 9 covers equipment purchasing and hygienic design controls in great detail, as these were the most frequently identified non-conformities of Issue 8.
FAQs
What are the key changes in BRCGS Issue 9 compared to Issue 8?
The significant updates made in BRCGS Issue 9 are a mandatory food safety culture plan, introduction of blended audit, mandatory HACCP validation, and additional requirements for equipment and hygienic design.
What are the BRCGS Issue 9 requirements for Indian food manufacturers?
Indian food producers should have documented food safety culture plan, validation of food safety plans before implementation, and presence of senior management during certification audit.
What changed from BRCGS Issue 8 to Issue 9 regarding audits?
BRCGS introduced in Issue 9 a third type of audit called ‘blended audit’, which allows to perform up to 50 percent of the announced audit remotely.
Is BRCGS Issue 9 mandatory for certified food manufacturers?
Yes, BRCGS Issue 9 became mandatory starting from 1 February 2023, while Issue 8 certification is not available anymore.
Does BRCGS Issue 9 change how HACCP plans are handled?
Yes, Issue 9 demands HACCP/FSMS validation before implementation and a special clause for traded goods.
How is food safety culture different under BRCGS Issue 9 vs Issue 8?
Culture was addressed as a single policy clause in Issue 8; however, in Issue 9, it must be part of a documented plan, activities must be measured, and it must undergo yearly review.
Will BRCGS Issue 9 be replaced soon by a newer issue?
There is development of Issue 10 by BRCGS; however, it will not be out until 2027.
