Specifications for Traded Products
Aligned with BRCGS Food Safety Issue 9 – Clause 5.3: Requirements for Traded Products
Requirement Overview
BRCGS Clause 5.3 requires that all traded products (i.e., products not manufactured on-site but sold under the site’s name or brand) be fully compliant with applicable safety, quality, and legal requirements. This includes maintaining up-to-date specifications, supplier assurance, and ensuring appropriate traceability and labeling controls.
Clause 5.3.1: “The company shall have a procedure for the approval and monitoring of suppliers of traded food products to ensure that traded food products are safe, comply with legal requirements and are manufactured in accordance with any defined product specifications.”
Specifications for traded products serve as the foundation for supplier approval, product verification, and label compliance—ensuring the same rigor is applied to outsourced items as those made in-house.
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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✓ Ensure all traded products meet food safety, legal, and quality standards
✓ Maintain up-to-date specifications for all traded products
✓ Verify label compliance and allergen declarations
✓ Support traceability and supplier accountability
Step-by-Step Compliance Implementation
1. Establish Supplier Approval for Traded Products
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Approval Process Should Include:
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• Risk-based assessment of the traded product supplier
• Verification of supplier certifications (e.g., GFSI-recognized schemes)
• Quality and food safety history review
Evidence to Maintain:
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• Supplier approval procedure
• Copies of third-party certifications or audits
• Supplier performance records
- • Risk-based assessment of the traded product supplier • Verification of supplier certifications (e.g., GFSI-recognized schemes) • Quality and food safety history review
- • Supplier approval procedure • Copies of third-party certifications or audits • Supplier performance records
2. Maintain Accurate Product Specifications
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Specifications Must Include:
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• Product description and composition
• Packaging, storage, and shelf life information
• Country of origin
• Allergen content and control measures
• Microbiological, chemical, and physical standards (if applicable)
Evidence to Maintain:
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• Signed and dated product specification sheets
• Specification review/change history
• Supplier-validated product data
- • Product description and composition • Packaging, storage, and shelf life information • Country of origin • Allergen content and control measures • Microbiological, chemical, and physical standards (if applicable)
- • Signed and dated product specification sheets • Specification review/change history • Supplier-validated product data
3. Verify Labelling and Legal Compliance
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Controls to Implement:
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• Ensure traded product labels meet local regulatory requirements
• Validate allergen declarations and claims
• Confirm label accuracy against product specs
Evidence to Maintain:
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• Approved label proofs and translations
• Label compliance checklist
• Internal or third-party review documentation
- • Ensure traded product labels meet local regulatory requirements • Validate allergen declarations and claims • Confirm label accuracy against product specs
- • Approved label proofs and translations • Label compliance checklist • Internal or third-party review documentation
4. Review and Update Regularly
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Update Triggers Include:
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• Changes to formulation, packaging, or supplier
• Regulatory changes impacting labels or allergens
• Internal findings or audit results
Evidence to Maintain:
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• Annual specification review log
• Version-controlled specification archives
• Change control records with impact assessment
- • Changes to formulation, packaging, or supplier • Regulatory changes impacting labels or allergens • Internal findings or audit results
- • Annual specification review log • Version-controlled specification archives • Change control records with impact assessment
Common Audit Findings & Recommended Fixes
| Audit Finding | Recommended Action |
|---|---|
| No specification available for traded product | Request signed specs from supplier and file centrally |
| Outdated supplier certifications | Implement renewal tracking system for supplier documents |
| Label non-compliance (e.g., missing allergen info) | Add internal label verification step before product approval |
| No evidence of specification review | Maintain dated review logs and responsible personnel records |
