BRCGS Consumer Products Issue 4 vs Issue 5: The Changes at a Glance

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

Issue 5 is the first full revision of the BRCGS Consumer Products standard since 2016, and based on the consultation draft it is a substantial one. This post gives you the comparison at a glance. For the in-depth version, my full article on the Issue 5 consultation draft goes through everything section by section.

The Structural Changes

Two standards become one. Issue 4 split the scheme into Personal Care and Household, and General Merchandise. Issue 5 merges them into a single standard covering the full non-food consumer products scope, with a revised product category structure that carries existing certificated categories across.

Foundation and Higher levels disappear. Issue 5 has one level of achievement. If you are currently certificated at Foundation level, this is the change that affects you most, and I have written separately about what Foundation certificated sites should be doing now.

Risk assessment is formalised. Issue 5 brings product risk assessment and process risk assessment together under a structured hazard analysis and risk assessment methodology, HARA. If your current system treats risk assessment as a form you fill in once a year, expect a step change. My explainer on what HARA actually involves covers the methodology.

Two new sections. Enhanced hygienic conditions for products where microbiological contamination matters, cosmetics and personal care being the obvious candidates, and a voluntary traded products section for sites that store and sell products they do not manufacture.

The Protocol Changes

The audit protocol aligns with the wider BRCGS family: a new blended announced audit option combining a remote records review with an on-site audit, plus grades for voluntary unannounced audits, multi-site certification in tightly defined circumstances, and a 3 working day requirement to notify your certification body of significant product safety or legality incidents. I have covered the audit options in detail here.

What This Means in Practice

The direction of travel is clear: Consumer Products is being brought up to the maturity of the food-facing BRCGS standards, with more formal risk methodology, more documented evidence and fewer places for a weak system to hide. Sites with robust Issue 4 systems at Higher level will recognise most of it. Sites at Foundation level, or sites that have coasted, have real work ahead of them, and the clock runs out in April 2027.