How to Run a BRCGS Issue 4 to Issue 5 Transition Project

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

Every standard revision produces the same two kinds of site. The first treats the transition as a project, with a plan, an owner and a deadline, and sails through their first audit against the new issue. The second assumes their existing system will stretch, and finds out on audit day that it does not. Having supported sites through multiple BRCGS and ISO transitions, I can tell you the difference is rarely capability. It is structure. Here is the structure.

Phase 1: Now, Before Publication

Start with dates. Use the Issue 5 timeline to establish exactly when your first Issue 5 audit falls, because that date drives everything else. Then appoint an owner. Someone senior enough to commit resource, with the transition as a named responsibility rather than an assumption.

Next, orientate. Understand the headline differences between Issue 4 and Issue 5 and identify your exposure areas. Ask three questions. Are we currently Foundation level, in which case read my Foundation level article today? Do our products plausibly trigger the enhanced hygiene expectations, which most cosmetics and personal care products will? And is our risk assessment genuinely a living methodology or a document we dust off annually?

What you should not do yet is rewrite documentation against the consultation draft. Clause numbers and wording will change before the final text. Build capability now, build documents later.

Phase 2: October 2026, at Publication

The week the final standard publishes, run a clause-by-clause gap analysis against your current system. Score each requirement honestly: compliant, partial, or absent. Convert the gaps into a corrective action plan with owners and completion dates that land at least two months before your audit, because you need time for the changes to generate records. An auditor can tell the difference between a procedure written last month and a procedure that has been producing evidence for a quarter.

Phase 3: The Final Run-In

Complete at least one full internal audit against the new requirements, prioritising the Fundamental requirements, since a major non-conformity against a Fundamental is the difference between a grade and no certificate. Test your traceability system properly in both directions. Brief senior management, because they will be expected to participate in the audit and speak to the culture plan. Then walk in confident.

If you want the gap analysis and transition planning done with you rather than by you alone, that is exactly what my remote consultation service covers. Use the site button below and tell me your audit due date.