BRCGS Consumer Products Issue 5 Changes: What Is New and What It Means for Your Site

By Robert Low, Lead Management System Specialist and BRCGS Approved Trainer

Now that Issue 5 is published, the question I hear most is simple: what has actually changed? Here is my plain English tour of the main BRCGS Consumer Products Issue 5 changes, what each one means for a real site, and where I expect people to get caught out. This is my own interpretation of the published standard, so always read the official text for the definitive wording.

One Standard, One Level

Under Issue 4 there were two standards, each with a Foundation and a Higher level. Issue 5 replaces all of that with a single standard and a single level of achievement covering the whole non-food consumer products scope. If you were certificated at Foundation, expect the biggest step up, because the expectations now sit at one consistent bar. If you were at Higher, you will recognise a lot, but clauses have been moved and reworded, so do not assume your existing procedures still point at the right requirement.

Product Categories Have Been Redrawn

The categories are now built around how products are made, not what they are sold as. Items such as medical devices, games and toys are placed in a category according to their material and fabrication, for example plastic, metal or textile. A site works out its categories with its certification body, and the categories feed into audit time and into the choice of a suitably qualified auditor. Getting this right early avoids an awkward conversation when the audit is being planned.

Risk Assessment Comes Together

For the first time the standard puts design, development and product risk assessment alongside process risk assessment, in a logical order. The process side is the hazard analysis and risk assessment plan, usually shortened to HARA. In practice this means your risk thinking has to run from the product idea through to the manufacturing process, instead of living in two separate documents that never meet.

Two New Sections

Section 7, enhanced hygienic conditions, only applies where legislation requires it for microbiological contamination, or where your own risk assessment shows the finished product can support microbial growth or survival. You will be expected to show that risk assessment to your certification body when the audit is planned. If you make anything wet, creamy or otherwise friendly to microbes, start here.

Section 8, traded products, covers products you buy in and sell on. It is an all or nothing choice, and I cover it in detail in a separate post.

More Ways to Be Audited

There are now three audit options. The announced audit and the voluntary unannounced audit carry on, and a blended announced audit has been added for re-certification. In a blended audit part of the audit is done remotely using technology, and the rest is on site. It is only offered after the certification body has assessed that a robust audit is possible, and only up to half the audit time can be remote. Check your customers are happy with this option before you choose it.

A Three Working Day Clock

If you have a significant product safety or legality incident, you now have to tell your certification body within 3 working days. That sounds obvious until you ask who in your business owns that call, and whether they know what counts as significant. I would want that answer written down before an incident, not during one.

Some Requirements Are Phased In

Certification against Issue 5 commences from 1 June 2027, but not everything bites on day one. A few requirements are deliberately delayed. The action plan for your product safety culture is not auditable until 1 June 2028, and the review of how effective that plan has been follows from 1 June 2029. The review of how well your product defence plan is working, and the supply chain vulnerability assessment, are also not auditable until 1 June 2028. Plan for them, but do not panic about them in year one.

My Model: The Three Clocks

When sites ask where to start, I get them to think in three clocks.

Clock one: which issue applies to you. An audit before 1 June 2027 is Issue 4. From that date it is Issue 5. Work this out from your certificate and your audit window, and confirm it in writing with your certification body.

Clock two: your readiness runway. Count back from your audit date. Your gap analysis, your changes and your internal audit all have to be finished early enough to leave records behind them, because an auditor wants evidence the system has been working, not a document written last week.

Clock three: the phased dates. Mark 1 June 2028 and 1 June 2029 in the plan now, so the delayed requirements arrive as planned work, not as surprises.

You can check which issue applies to your next audit with the free audit checker on my BRCGS Consumer Products 5 guide.

Where Sites Get Caught Out

The mistake I see most is treating this as a document update. Moved and reworded clauses mean old cross references quietly break, and a changed requirement needs a changed practice, not just a changed paragraph. The second is leaving the gap analysis until the autumn before the audit, which leaves no time to generate evidence.

Over the coming days I will go through the governance and audit changes, then each section of the standard in turn. If you would rather have someone walk your system against Issue 5 with you, my remote gap analysis and consultancy are built for exactly that.