Approval & Verification of Traded Products
Aligned with BRCGS Food Safety Issue 9 – Section 5.9
Requirement Overview
BRCGS Food Safety Issue 9, Section 5.9, applies when a certified site trades food products manufactured by other companies but sold under the certified site’s name or handled through its processes (e.g., warehousing, labeling, distribution).
Clause 5.9.1: “The company shall ensure that traded food products comply with all relevant safety, legal, and quality requirements.”
Clause 5.9.2: “There shall be documented procedures for supplier approval, risk assessment, and verification of traded products.”
Sites must treat traded products with the same level of control as in-house produced items—ensuring they meet food safety, legal, and quality standards through formal supplier approval and verification procedures.
Aligned with BRCGS for Storage & Distribution Issue 4 – Clause 4.3.1 & 4.3.3
Requirement Overview
BRCGS for Storage & Distribution requires that products moved via cross-docking are traceable and controlled at all times, even when they are not held in storage for extended periods.
Clause 4.3.1: “The company shall ensure that traceability is maintained at all stages, including during cross-docking operations.”
Clause 4.3.3: “Procedures shall be in place to ensure that all products handled, including those not stored on-site, remain under control and are not subject to contamination or substitution.”
Cross-docking operations must not compromise product traceability, safety, or integrity. Even with minimal handling and temporary presence, each product must be accurately identified, documented, and protected.
Key Compliance Objectives
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✓ Approve traded product suppliers through documented procedures
✓ Conduct food safety and legal compliance checks
✓ Maintain traceability and verification documentation
✓ Ensure consistent quality and risk control of all traded products
Step-by-Step Compliance Implementation
1. Establish Supplier Approval Criteria
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Approval Must Be Based On:
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• Risk assessment of each traded product
• Supplier food safety certification (e.g., GFSI-recognized scheme)
• Review of HACCP plans, COAs, and product specifications
Evidence to Maintain:
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• Supplier approval procedure
• Risk assessment forms per traded product
• Supplier certification or audit summary
- • Risk assessment of each traded product • Supplier food safety certification (e.g., GFSI-recognized scheme) • Review of HACCP plans, COAs, and product specifications
- • Supplier approval procedure • Risk assessment forms per traded product • Supplier certification or audit summary
2. Verify Ongoing Supplier Compliance
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Verification Methods May Include:
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• Supplier performance reviews and issue logs
• Random product sampling or third-party testing
• Documented reassessment schedule (e.g., annually)
Evidence to Maintain:
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• Supplier monitoring records
• Retest results, complaints, or incident logs
• Approved supplier list with review dates
- • Supplier performance reviews and issue logs • Random product sampling or third-party testing • Documented reassessment schedule (e.g., annually)
- • Supplier monitoring records • Retest results, complaints, or incident logs • Approved supplier list with review dates
3. Maintain Traded Product Specifications
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Specifications Must Include:
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• Ingredient/allergen details
• Packaging requirements
• Storage and shelf life parameters
• Labelling and country-of-origin declarations
Evidence to Maintain:
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• Signed product specifications from supplier
• BRCGS-compliant label and allergen check
• Product conformance records
- • Ingredient/allergen details • Packaging requirements • Storage and shelf life parameters • Labelling and country-of-origin declarations
- • Signed product specifications from supplier • BRCGS-compliant label and allergen check • Product conformance records
4. Ensure Legal & Food Safety Compliance
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Key Considerations:
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• Country-specific regulatory requirements
• Import/export documentation (if applicable)
• Any known or emerging product risks
Evidence to Maintain:
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• Regulatory compliance checklist
• Country of destination requirements log
• Food fraud vulnerability assessment (if applicable)
- • Country-specific regulatory requirements • Import/export documentation (if applicable) • Any known or emerging product risks
- • Regulatory compliance checklist • Country of destination requirements log • Food fraud vulnerability assessment (if applicable)
Common Audit Findings & Recommended Fixes
| Audit Finding | Recommended Action |
|---|---|
| No documented supplier approval | Implement and follow a formal supplier approval process |
| No risk assessment for traded goods | Conduct and retain risk evaluations for all traded products |
| Outdated or missing product specs | Ensure specs are reviewed, signed, and regularly updated |
| Inadequate verification | Monitor supplier performance and update approved supplier list |