BRCGS Consumer Products Issue 5 Draft: Every Key Change Explained

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

The BRCGS Consumer Products Issue 5 draft is the first full revision of the standard since Issue 4 launched in 2016. Nine years is a long time in FMCG manufacturing, and it shows. This is not a light refresh. The structure has been rebuilt, the risk assessment methodology has been formalised, two entirely new sections have been added, and the audit protocol has been brought into line with the rest of the BRCGS family.

I have been through the consultation draft in detail, submitted feedback to BRCGS, and signed as a formally invited Principal Trainer for Issue 5, with preparation work starting in August 2026. So this is not a summary written from a press release. This is what is actually in the document, what it means for certificated sites, and what you should be doing about it now.

The Headline Changes

One standard. Issue 4 split Consumer Products into two standards, Personal Care and Household, and General Merchandise. Issue 5 merges them back into a single standard covering the full non-food consumer products scope. If you currently hold certification under either standard, your product categories carry over into the revised category structure.

One level of achievement. Foundation and Higher levels are gone. Every site is now audited against one set of requirements. For sites currently certificated at Foundation level, this is the single biggest practical consequence of Issue 5, because the bar has effectively moved up to a unified level and there is no lower tier to sit in.

A restructured framework. The section layout has been reorganised. Product risk assessment and process risk assessment now live together in a new Section 2. Equipment maintenance, contamination control and foreign body detection have moved into site standards. Process control and product inspection have been combined. If you know Issue 4 well, expect to spend real time re-mapping your system against the new clause numbering.

Two new sections. Section 7 introduces enhanced hygienic conditions for sites whose products are subject to hygienic manufacturing legislation, cosmetics being the obvious example, or where risk assessment shows the finished product can support microbiological growth or survival. Section 8 introduces voluntary requirements for traded products, letting sites bring purchased products they store but do not manufacture into their audit scope.

Audit Protocol Changes

The protocol has been revised to align with other BRCGS standards, and it incorporates the Position Statements issued under Issue 4. The changes that matter most:

Blended announced audits are new. Issue 5 introduces a two-part audit option: a remote audit of documented systems and records using information and communication technology, followed by an on-site audit focused on production, storage and the factory floor. It is only available for announced recertification audits, never for a site’s first audit, and only where the certification body’s risk assessment confirms a robust audit is achievable remotely. For multi-national groups and sites with mature electronic systems, this is a genuinely useful option.

Voluntary unannounced audits carry a distinct grade. Sites opting into the unannounced programme receive a plus grade, AA+ through D+, signalling audit-ready maturity to customers. The unannounced audit can land at any point in the final four months of the audit cycle, and sites may nominate up to ten days when an audit genuinely cannot take place, with at least four weeks notice to the certification body. Initial audits are always announced.

Multi-site certification is now possible in defined circumstances. Where a company operates additional facilities under common management as a single operation, these can be included under one certification, provided all sites share ownership and the same documented management system, the sites perform sequential steps of the same manufacturing process, they supply only each other, and they sit no more than 30 miles or 50 km apart. All locations must be visited within the same audit schedule. This mirrors what other BRCGS standards already allow.

Incident notification is now a clock, not a courtesy. A significant product safety or legality incident must be notified to your certification body within 3 working days, with sufficient information for the certification body to assess certificate validity, including corrective action, root cause analysis and a preventive action plan, within 21 calendar days.

Audit duration is under review. The Technical Working Group is rebuilding the audit duration calculator to reflect the scale of the changes. Expect a minimum in the region of 1.5 days on site, with the calculator published after launch. Sites budgeting for 2027 audits should not assume Issue 4 durations will carry over.

The Requirements: What Has Actually Changed

Section 1: Senior management commitment. Management review gets its own sub-section with a defined evaluation agenda covering audit results, complaints, incidents, unmet objectives and the effectiveness of HARA, product defence, fraud prevention and culture plans. The product safety and quality culture plan is now far more prescriptive, requiring defined activities around communication, training, personnel feedback and behaviours, and it phases in over time: the documented action plan with timescales becomes auditable from 5 April 2028, and the review of effectiveness from 5 April 2029. A confidential reporting system for personnel to raise product safety, legality and quality concerns is also required, with a documented process for assessing what comes in.

Section 2: Product and process risk management. This is the biggest structural change in the draft, and it is a Fundamental. Section 2 now combines design, development and product risk assessment with a full hazard analysis and risk assessment methodology, HARA, built out in the recognisable step-by-step pattern: assemble a multi-disciplinary team with a trained leader, establish prerequisite programmes, describe the product, construct and verify process flow diagrams, identify hazards at each manufacturing step, determine control measures, establish and validate limits, monitor, define corrective action plans, then validate and verify the whole plan with at least annual review. Anyone who works with the Food Safety standard will recognise the architecture immediately. Product risk assessments must now explicitly consider susceptibility to microbiological growth or survival, which is the trigger for the Section 7 assessment, and technical file requirements have been folded into this section too.

Section 3: Product safety and quality management. Two genuinely new sub-sections appear here. Management of outsourced processes covers intermediate manufacturing steps or storage completed off site before the product returns, including home workers, with batch release procedures for returning goods and final release always remaining the site’s responsibility. Management and approval of suppliers of services formalises what many sites did loosely under Issue 4, with a defined list spanning pest control, laundry, cleaning, transport, laboratories, calibration, waste, consultants and agency labour providers. Supplier approval routes are spelled out in more detail, internal audit programmes must now spread across at least two non-consecutive dates in the year, and incident management picks up the 3 working day certification body notification described above. Traceability keeps its Fundamental status, with tests at least annually and a 4 hour target for achieving traceability.

Section 4: Site standards. Security becomes site security and product defence, requiring a documented threat assessment covering internal and external threats and a product defence plan reviewed at least annually, with the review of its effective implementation auditable from 5 April 2028. A new utilities sub-section covers water quality, a schematic of the water distribution system, and the microbiological and chemical quality of steam, ice, air and compressed gases contacting product. Equipment maintenance, chemical, sharps, glass and brittle material controls, foreign body detection and removal equipment, and a new allergen and sensitising materials management plan all now sit within this section.

Section 5: Product and process control. Incoming goods control is elevated to a Fundamental in its own right. The genuinely new content is product vulnerability: a documented vulnerability assessment of all materials, components and packaging against substitution, adulteration and misrepresentation, informed by horizon-scanning of supply chain threats. Product fraud thinking has formally arrived in Consumer Products, and the two core vulnerability clauses become auditable from 5 April 2028. Line clearance gets its own explicit requirements, as do dispatch and transport, storage facilities, calibration, finished product packing and positive product release.

Section 6: Personnel. Largely a consolidation of Issue 4, with training and competence remaining Fundamental, but with a new medical screening sub-section requiring a notification procedure for infectious diseases or conditions where there is a risk to product safety, and hygiene requirements that are explicitly risk-assessment led, covering jewellery, wrist-worn devices, fingernails and taint from fragrance.

Section 7: Enhanced hygienic conditions. Entirely new, and the section that cosmetics, personal care and hygiene product manufacturers need to read most carefully. If your products are subject to hygienic manufacturing legislation on microbiological contamination, or your risk assessment shows finished products can support microbiological growth or survival with potential harm to the consumer, Section 7 applies on top of Sections 1 to 6. It covers segregated hygiene areas and flow, drainage and air handling, treated and monitored water used as an ingredient, exclusion of wood, dedicated changing facilities and visually distinct protective clothing, validated cleaning and sanitation, and tighter personal hygiene rules including a ban on false nails and varnish in the enhanced areas. For a cosmetics site already running ISO 22716, much of this will feel familiar, but it now needs to be demonstrably mapped and evidenced within your BRCGS system.

Section 8: Traded products. Also new, and voluntary. Sites storing purchased products that fall within the standard’s scope but are not manufactured, reworked or packed on site can opt to include them in the audit. It is all or nothing: you cannot cherry-pick some traded products and exclude others. The section covers a HARA plan for the traded operation, approval and performance monitoring of the last manufacturer or packer, specifications, risk-based inspection and testing, legality verification and full traceability back to the manufacturer and forward to the customer, tested at least annually.

The Fundamentals. Eleven statements of intent carry Fundamental status in the draft: senior management commitment, product and process risk management, internal audits, traceability, corrective and preventive actions, layout and segregation, housekeeping and hygiene, incoming goods control, product inspection and laboratory testing, manufacturing process control, and training and competence. A major non-conformity against any of these means no certificate at an initial audit, or withdrawal at a recertification audit, followed by a further full audit. Build your internal audit programme around these first.

Rough Edges in the Draft, and the Feedback I Submitted to BRCGS

Because this is a consultation draft, it contains what you would expect a consultation draft to contain: internal misalignments. There are clause numbering inconsistencies, cross-references that point to the wrong sub-sections, and at least one duplicated clause number. None of this is unusual at consultation stage, and I would expect it to be tidied before the October 2026 publication, but it does mean nobody should be building transition documentation against the draft’s clause numbers yet.

I submitted a completed feedback form to BRCGS within the consultation window. Everything below is my personal opinion as a practising auditor and trainer. BRCGS may or may not take any of it on board, and none of it should be read as an indication of what the final text will say. But these are the points I felt strongly enough about to put on record.

The missing CCP is my biggest concern. The draft builds a complete HARA methodology, hazard identification, control measures, validated limits, monitoring and corrective action, without ever designating anything as a Critical Control Point. The phrase simply does not appear. In my view that is a mistake. CCP is one of the most valuable and widely understood terms in the entire BRCGS vocabulary, and removing it risks large-scale misunderstanding across sites and auditors alike. It gets worse: the official BRCGS HARA training uses the term CCM, which does not appear in the draft either, so the standard and the training that supports it would be speaking different languages. Packaging Materials Issue 7 handles this far better with its step to determine the critical control measures, which is immediately understandable. My feedback was to pick one term, anchor it in the standard, and align the training to it.

Traceability testing needs a rethink. Two points here. First, the requirement still leans on vice versa style wording to describe testing in both directions, and in my experience that phrasing is one of the most commonly misunderstood parts of the current standard. Packaging Issue 7 spells it out explicitly, raw materials forward to the customer and finished product backward to raw materials, and I fed back that adopting that clarity here would save a lot of sites from getting the test wrong. Second, the 4 hour target for achieving traceability strikes me as arbitrary. These are consumer products with long shelf lives, not chilled food, and there is no obvious safety benefit to a 4 hour window that a 48 hour window would not deliver. Most consumer products sites are simply not set up for a 4 hour turnaround, and my suggestion was a more realistic baseline with measured year-on-year improvement instead.

Say documented when you mean documented. A recurring niggle throughout the draft is inconsistency between clauses that demand a documented procedure and near-identical clauses that only ask for a process, an assessment or a register. Labelling review, supplier performance monitoring and dispatch all use softer phrasing than their sibling clauses, the product defence clause asks for an assessment where the pest management clause asks for a documented risk assessment, and the chemical and glass registers are not explicitly documented registers, something I have seen sites overlook too many times to count. Auditors and sites read these wording differences as deliberate. If the intent is documented evidence, the clause should say so. While we are on terminology, the draft still refers to material safety data sheets. That phrase is outdated. The globally harmonised term is Safety Data Sheet, and a new issue of the standard should use it.

Observations from the factory floor. Several of my comments came straight from things I see on audits. The restriction on staples, paper clips and drawing pins applies to exposed product areas, but plenty of sites do not treat storage as exposed, then sample and inspect product right there, which makes it an open product area for exactly the time that matters. I suggested extending the wording to cover areas where product is inspected. Notices and document holders near equipment should be required to be in good condition as well as secure, because I regularly find them with missing parts and delaminating laminate, which is prior damage waiting to become contamination. Where risk assessment determines protective clothing requirements, I asked whether that assessment must be documented, because as written a verbal risk assessment could arguably satisfy it. The laundering clause would benefit from an explicit link back to the approval of service suppliers. The requirement to routinely review personnel competencies needs a defined frequency, annually or on HARA change, because routinely is not auditable. And on personnel facilities, one I see constantly: out-of-date food sitting in staff fridges and cupboards, which I would argue is a personnel health issue the standard could and should capture.

On the protocol itself. My general feedback was that the scheme should go further than a voluntary unannounced option and adopt a 1 in 3 unannounced audit programme, the model other BRCGS standards use. A consistent unannounced element is what actually catches the sites that spend weeks prepping and polishing for a known audit date. I also said plainly that the blended audit option is a fantastic addition to the scheme. And on the audit duration calculator, it needs to be explicit about whether plant size means floor area, because I have audited manufacturing spread across six floors of a tower where the vertical footprint was never factored in and the audit duration came out wrong as a result.

Whether any of this survives the Technical Working Group’s review, we will find out in October 2026. That is exactly what consultation is for.

Is Your Next Audit Issue 4 or Issue 5? Work It Out Now

The transition rule is simple, but I am already seeing it explained badly. The published timeline is: consultation closed 22 January 2026, Issue 5 publishes October 2026, and certification audits against Issue 5 commence in April 2027. Every audit carried out before April 2027 is against Issue 4, and those certificates remain valid for the period stated on them. Every audit from April 2027 onwards is against Issue 5. There is no choosing between the two.

Worked examples on a standard 12 month cycle:

Audit due May to June 2026: Issue 4. Your following audit in May to June 2027 falls after the April 2027 commencement, so that one is Issue 5. Your Issue 4 certificate issued in 2026 is effectively your last one.

Audit due January to March 2027: Issue 4, and among the very last Issue 4 audits conducted. Your 2028 audit will be Issue 5.

Audit due April 2027 or later: Issue 5, full stop. If your audit due date sits in April, May or June 2027, you have the shortest possible runway between the October 2026 publication and your first Issue 5 audit. You should be gap-assessing against the final standard the week it publishes.

Why does this matter so much? A cosmetics manufacturer I know well had their Issue 4 audit in mid 2025 and were told by their auditor, informally, that their subsequent audits would also be against Issue 4, with no mention of the April 2027 cut-over. Follow that advice literally and you arrive at a mid 2027 audit having prepared for the wrong standard, facing a merged standard, no Foundation level, a full HARA requirement and potentially Section 7 obligations you have never gap-assessed. Against a standard where a single major non-conformity on a Fundamental means certificate withdrawal, that is not a small administrative slip. It threatens retailer listings and contracts. Check your own audit due date against April 2027 today, and do not rely on corridor advice, even from your auditor. Verify against the published protocol.

I Will Be Training This Standard. Here Is How That Works

I can share that I have been formally invited by BRCGS to act as a Principal Trainer for the Global Standard Consumer Products Issue 5. The agreement is signed and preparation work begins in August 2026, ahead of the October 2026 publication. I will be delivering the official ATP training courses for Issue 5 as soon as the standard goes live.

The training rollout follows the same sequence every BRCGS revision does: auditors are trained first, then sites. Certification body auditors must complete their Issue 5 conversion training before they can audit against the new standard, which means CB training demand lands hard in late 2026 and early 2027, before the April 2027 audit commencement. Site training follows, so that sites are prepared before their first Issue 5 audit lands.

If you are a certification body, get in touch now. Auditor conversion training slots ahead of April 2027 are finite, and the CBs that book early will have their auditor pools converted with time to spare rather than scrambling in Q1 2027. Use the certification body button at the end of this article and it will open a pre-filled email straight to me, so I can respond with dates rather than questions.

For manufacturing sites, I will be delivering official Issue 5 site training courses once the auditor phase is underway, and in the meantime I offer remote consultation services to get you ahead of the transition: a structured Issue 4 to Issue 5 gap analysis against the final published text, a review of whether Section 7 enhanced hygienic conditions applies to your products, HARA development support for teams building the methodology for the first time, and transition planning mapped to your specific audit due date. All of it delivered remotely, so it works whether you are in Norwich or anywhere else in the world.

Issue 5 is the biggest change to this standard in a decade. The sites that treat the period between October 2026 and their first Issue 5 audit as a project, with a plan, an owner and a deadline, will sail through. The sites that assume their Issue 4 system will stretch to cover it will find out otherwise on audit day.