BRCGS Gluten-Free Certification System Requirements
Guidance Aligned with BRCGS Global Standard for Gluten-Free Certification
Published by Food Safety Systems | A Service by Consultare Inc. Group – A Compliance Company
Food businesses producing gluten-free products must implement rigorous controls to meet regulatory requirements and protect consumers with celiac disease or gluten sensitivity. The BRCGS Gluten-Free Certification provides recognized proof of compliance with global gluten-free standards (<20ppm gluten content).
This guide provides a practical checklist to help manufacturers, packers, and food service operators implement certification-ready systems.
BRCGS Gluten-Free Compliance Checklist
1. Leadership Commitment (Clause 1)
✓ Document a gluten-free policy signed by senior management
✓ Appoint a Gluten-Free Product Team with defined responsibilities
✓ Conduct annual management reviews of gluten-free controls
2. Risk Assessment & Control (Clause 2)
✓ Conduct thorough gluten hazard analysis (including supply chain)
✓ Identify and validate Critical Control Points (CCPs)
✓ Maintain gluten risk assessment documentation
3. Site & Production Controls (Clause 3)
✓ Implement dedicated production lines or validated changeover procedures
✓ Establish “positive release” system for gluten-free products
✓ Control rework to prevent cross-contact
4. Supplier Management (Clause 4)
✓ Approve suppliers through gluten risk assessments
✓ Require gluten-free statements/certificates for all ingredients
✓ Conduct supplier audits for high-risk materials
5. Ingredient & Product Specifications (Clause 5)
✓ Maintain detailed gluten-free specifications for all materials
✓ Verify gluten-free status through certificates of analysis
✓ Document product formulations with gluten content calculations
6. Processing & Equipment (Clause 6)
✓ Validate cleaning procedures between gluten-containing runs
✓ Implement equipment dedication or segregation
✓ Control maintenance tools to prevent cross-contact
7. Labeling & Claims (Clause 7)
✓ Verify all labels meet FDA/EC gluten-free regulations
✓ Implement label approval process with technical review
✓ Control packaging materials to prevent mix-ups
8. Testing & Verification (Clause 8)
✓ Establish gluten testing protocol (ELISA R5 ELISA recommended)
✓ Conduct periodic product testing (minimum quarterly)
✓ Maintain laboratory competency records
9. Training (Clause 9)
✓ Train staff on celiac disease risks and gluten controls
✓ Provide specialized training for gluten-free team members
✓ Document training attendance and competency checks
10. Internal Audits (Clause 10)
✓ Audit gluten-free system annually
✓ Verify implementation of all control measures
✓ Document corrective actions for non-conformities
Support for Gluten-Free Certification
We provide complete solutions for BRCGS Gluten-Free compliance:
Documentation Tools
• Gluten-free policy templates
• Supplier questionnaires
• Risk assessment frameworks
Implementation Support
• Gap assessments
• Process validation guidance
• Mock audits
Testing Resources
• Approved lab partnerships
• Sampling protocols
• Test method validation
Ready for Gluten-Free Certification?
Let us help you build a system that’s efficient, auditable, and globally aligned.
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Reference & Disclaimer
This content aligns with BRCGS Gluten-Free Certification requirements. For official certification, always refer to the full standard at www.brcgs.com.
