Issue Four of the BRCGS Global Standard Gluten-Free has now been released. In this article, we will explore the key changes and additions to this new publication.

With an initial release date of 1st November 2023 and a plan to commence audits on 1st May 2024, Issue 4 of the BRCGS Global Standard Gluten-Free was launched a little later than expected – published on February 6th 2024, with audits commencing on 1st August 2024. This delay allowed time for further development, with the new standard delivering unprecedented levels of assurance and value to its stakeholders.

Globally applicable, and with certified sites in 35 countries, Issue Four of the BRCGS Global Standard Gluten-Free features an additional segment (Section Eight) that has been introduced in partnership with the Association of European Coeliac Societies (AOECS). As a consequence, certified sites, along with the brands that source from them, will be able to display the organisation’s crossed grain symbol on their packaging – the most recognised gluten-free symbol across Europe.

Alongside the launch, BRCGS highlighted the fact that 91% of consumers have found their buying decisions are impacted by third party verification and 76% prefer products that have been certified by a recognised coeliac association. With this in mind, we felt it was important to unpack such an important publication, guiding you through any changes or additions.

The following article consists of seven sections. You can use the links below to skip to the ones most relevant to your needs, but there are useful takeaways throughout:

Clarity, Consistency, and Colour-Coding

Smaller, more manageable clauses

In the interest of making the Global Standard Gluten-Free easier to understand and adhere to, BRCGS has split the requirements into clauses that are far shorter than the ones featured in previous issues. The Standard offers the same amount of detail, in fact even more guidance has been added, but the clauses themselves are a more manageable length.

The removal of two Appendices

Another point of interest is that two Appendices from Issue 3 of the Global Standard Gluten-Free will be absent from Issue 4. The content will be available, but in the form of standalone guidance documents. These documents will be subject to periodic review.

Colour-coding of requirements

The requirements have now been colour-coded to indicate which elements will be audited as part of the assessment of the production areas and facilities and which elements will be audited as part of the assessment of the records system and documentation. The former will be a pale yellow, the latter will be grey, and any combined elements will be both colours.

Position Statements from Issue 3

In an effort to be consistent with the other Standards from BRCGS, the terminology featured in Issue 4 has been updated. You may also notice that the Position Statements relating to Issue 3 have now been incorporated into the new release.

The Grading of Non-Conformities

The non-conformities relating to Issue 4 of the Global Standard Gluten-Free have now been graded. This should make it easier for you to ensure your site meets the requirements of the Standard, as you will have a better understanding of the non-conformities or combination of non-conformities that will prevent your site from being certificated.

The grading process will inform the frequency of your audits, along with the actions that need to take place following any non-conformities. For example, if your site receives seven or fewer minor non-conformities, you will need to provide objective evidence of your efforts to resolve the non-conformities within 28 days and your site will be audited every twelve months. Alternatively, if your site receives a major non-conformity, alongside 6-8 minor non-conformities, there will be a revisit scheduled to review the corrective action.

Whenever you undergo an audit, the grading of any non-conformities will be reviewed by the independent certification process of the certification body. Throughout the lifetime of Issue 4, The BRCGS Technical Advisory Committee may also be asked to share a ruling on the grading of a non-conformity against a specific clause.

Labelling and Pack Control

One of the most noticeable changes between Issues 3 and 4 of the BRCGS Global Standard Gluten-Free is the addition of a section on Labelling and Pack Control. As Section 5 of the Standard, it includes guidance relating to product changeover and product label verification measures, along with packing line and packing area control measures. The three clauses in this section cover everything from the documented checks of your production line to the testing of online verification equipment e.g. bar code scanners. This guidance will help you to ensure the gluten-free products at your site are placed into the correct packaging and labelled correctly – protecting your customers and safe-guarding the future of your factory.

The Management of Outsourced Processing

Outsourced or Subcontracted Processing is when processing, storage, or another step in your production is completed by an external company or site. This term applies to a product that leaves your site partly-processed, has an intermediate step carried out externally, then returns to your site. Raw materials and ingredients that arrive at your site ready to be processed wouldn’t fall into this category and neither would a product that is sent out and does not return.

Clause 3.5 of the BRCGS Global Standard Gluten-Free relates to the Management of Outsourced Processing. Below are four key points from this portion of the Standard. It’s important to note that they are summarised extracts, so you will need to read the Standard itself to fully understand the requirements.

  • If any processes are outsourced, the risks associated with gluten need to be included in your site’s food safety (HACCP) plan.
  • The approval process for outsourced processing needs to include a review of the procedures to prevent contamination.
  • You need to be able to prove that the outsourced processor is certificated to the BRCGS Standard Gluten-Free or meets a specific list of requirements.
  • You need to establish inspection and test procedures for products where part of the processing has been outsourced.

Simplifying the 'Schedule A' Process

BRCGS defines Schedule A as “a control and tracking document, listing the gluten-free products produced at a site which are intended to display BRCGS-managed trademarks and/or the ACELMEX trademark”.

Issue 4 has seen the simplification of the Schedule A process for sites and certification bodies, with this topic covered in Section 6 of the Global Standard Gluten-Free. There are three clauses within this section:

  • Clause 6.1.1 details the correct approach to listing the products that display any of the trademarks covered by the Schedule A.
  • Clause 6.2.1 covers the communication of any amendments, listing the changes that sites are required to share with BRCGS.
  • Clause 6.3.1 explains what is required for a Schedule A to be considered valid e.g. signed and dated by BRCGS.

Information Communication Technology and Remote Auditing

BRCGS has also introduced the option of using information communication technology and remote auditing under specific circumstances. These circumstances include:

A blended announced audit. This is only an option for sites that have already been certified. A risk assessment will also need to be carried out beforehand to confirm a robust audit is possible and to assess the percentage of the audit that can be carried out remotely.

Once these points have been confirmed, the process will be split into a remote audit followed by an on-site inspection. The remote aspect will focus on the documented systems and records, whereas the on-site audit will take a closer look at gluten-free production, storage, and other on-site areas.

Information Communication Technology and remote auditing may also come into play during the closing-out of any non-conformities. Depending on the circumstances and the grading of the non-conformities, it may be possible to assess corrective actions, root cause analysis, and preventative action plans remotely. This decision will be made by the certifying body. If approved, either a remote audit of the corrective action will be carried out or suitable documentary evidence will be shared.

Finally, ICT and remote auditing could also be an option if you work for one of many sites, with multiple locations managed by a head office or central function. These centrally managed systems will need to be included within the audit and there are two ways for this to be achieved:

  • Any relevant information from the head office will be requested and reviewed during the audit of the site in question.
  • The head office will undergo a separate audit, splitting the auditing process into two distinct steps.

The first approach will only be possible is satisfactory links can be established with the central function and it is possible to review and challenge the necessary information remotely.

Section 8: AOECS Specific Requirements

Section 8 is perhaps the most exciting addition to Issue 4 of the BRCGS Global Standard Gluten-Free. Whilst Sections 1-7 are applicable to all operations, the requirements of Section 8 are reserved for sites that:

  • Produce products within the scope of the AOECS Standard
  • Can prove that they are, or intend to be, a Crossed Grain Trademark licence holder
  • Supply their products to actual or potential licence holders

Within Section 8 of the BRCGS Global Standard Gluten-Free, there are six clauses to consider:

  • Clause 8.1.1 relates to supplier approval and purchasing, incoming ingredients, and inputs.
  • Clause 8.2.1 outlines the expectations surrounding product recalls and withdrawal.
  • Clause 8.3.1 details the AOECS Standard for food labels used on Gluten-Free foods.
  • Clause 8.4.1 details the marketing claims that can be made alongside the trademark.
  • Clause 8.5.1 states the circumstances under which the crossed grain trademark can be used.
  • Clause 8.6.1 details the laboratory and testing requirements.

Access a copy of the BRCGS Global Standard Gluten-Free, Issue 4 using the button below.

If you would like any support in meeting the specifications outlined within Issue 4, Klipspringer has been helping sites to exceed audit expectations for over 20 years. We would be more than happy to provide help and guidance as you work through the requirements. You can contact us on 01473 461800 or sales@klipspringer.com. Alternatively, you can use the form below to arrange a consultation

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