BRCGS Issue 10: Anticipating the Next Evolution of the Standard

BRCGS (Brand Reputation through Compliance Global Standards) Food Safety Issue 9 brought significant changes to food safety culture, environmental monitoring, and supply chain transparency. As the industry works through the Issue 9 transition, attention is already turning to what Issue 10 will bring.

While BRCGS has not yet published a confirmed release date or draft for Issue 10, the standard's development trajectory — combined with GFSI benchmarking updates and evolving regulatory expectations — gives us a clear picture of where the standard is heading. This post outlines what manufacturers in Canada and the United States should anticipate and how to begin preparing.

The BRCGS Development Cycle

BRCGS typically revises its Food Safety standard every four to five years, with each edition responding to:

• GFSI benchmarking updates — BRCGS must maintain alignment with the Global Food Safety Initiative's benchmarking requirements to retain GFSI recognition
• Regulatory developments — including FSMA updates in the US, SFCR and CFIA guidance in Canada, and EU food law changes that affect global supply chains
• Industry consultation — BRCGS conducts extensive stakeholder consultation before each revision, gathering input from certified sites, certification bodies, retailers, and food safety experts
• Emerging food safety science — new research on pathogens, environmental contamination, food fraud, and allergen management informs each revision

Issue 9 was released in 2022. Based on the typical revision cycle, Issue 10 could be expected in the 2026–2027 timeframe, though BRCGS has not confirmed this.

What Is Anticipated in BRCGS Issue 10

Food Safety Culture: From Requirement to Demonstrated Outcome

Issue 9 made food safety culture a formal, auditable requirement for the first time. Issue 10 is expected to go further, shifting the focus from having a food safety culture programme to demonstrating measurable outcomes. Anticipated changes include:

• Quantitative metrics for food safety culture performance, with trend analysis required over time
• Stronger requirements for how culture findings feed into management review and continuous improvement processes
• Greater specificity around how culture is assessed across different shifts, departments, and levels of the organisation
• Expectations that culture improvement is treated as a continuous programme, not an annual exercise

For manufacturers, this means food safety culture needs to be woven into the fabric of daily operations — not managed as a separate compliance activity.

Technology, Automation, and Data Integrity

The food industry's rapid adoption of digital tools is reshaping how food safety management systems are implemented and verified. Issue 10 is expected to address this directly by:

• Introducing explicit requirements for data integrity in electronic food safety records
• Providing guidance on the use of automated monitoring systems for CCPs and OPRPs
• Addressing the use of artificial intelligence and machine learning tools in food safety monitoring and decision-making
• Requiring documented controls for cybersecurity risks that could affect food safety systems

This does not mean manufacturers must adopt new technology — but those using digital systems will need to demonstrate that their data is trustworthy, complete, and protected.

Environmental Monitoring: Greater Rigour and Scope

Issue 9 significantly strengthened environmental monitoring programme (EMP) requirements. Issue 10 is expected to build on this with:

• More prescriptive requirements around sampling frequency, particularly for high-risk zones and products
• Expanded scope for environmental monitoring beyond Listeria and Salmonella to include emerging pathogens relevant to specific product categories
• Stronger requirements for trend analysis and the use of EMP data to drive preventive action
• Clearer expectations around the validation of environmental monitoring methods

Facilities that have implemented a robust, risk-based EMP under Issue 9 will be well positioned. Those still developing their programmes will need to accelerate.

Supply Chain Integrity and Responsible Sourcing

Supply chain transparency has been a growing focus across all GFSI-benchmarked standards, and Issue 10 is expected to raise the bar further. Anticipated changes include:

• Faster traceability requirements, with mass balance exercises potentially required within two hours
• Stronger supplier approval and monitoring requirements, including more frequent re-evaluation of high-risk suppliers
• Expanded food fraud vulnerability assessment requirements, with greater emphasis on verification and testing
• Emerging requirements around responsible sourcing — including labour practices, environmental impact, and ethical supply chain considerations

The responsible sourcing dimension reflects growing retailer and consumer expectations around supply chain ethics, and is an area where BRCGS is expected to align with broader sustainability frameworks.

Allergen Management: Validation and Verification

Allergen management has been a focus of successive BRCGS editions, and Issue 10 is expected to introduce:

• Mandatory validation of allergen cleaning procedures for all facilities producing products with allergen risks
• Strengthened requirements for allergen labelling verification, including checks at multiple points in the production process
• Clearer requirements for managing allergen risks in shared facilities and on shared equipment
• Updated requirements for communicating allergen information through the supply chain

Given the severity of allergen-related recalls and the regulatory consequences in both Canada and the US, these updates will require careful attention from any facility handling allergenic ingredients.

Sustainability and Environmental Responsibility

A newer dimension emerging in global food safety standards is environmental sustainability. Issue 10 may begin to incorporate:

• Requirements or guidance around measuring and reducing the environmental impact of food manufacturing operations
• Consideration of climate-related risks in food safety hazard analysis
• Water stewardship requirements, particularly for water-intensive manufacturing processes
• Waste reduction and circular economy considerations

This reflects the direction of travel across major retailers and global food companies, many of which are setting ambitious sustainability targets and expecting their supply chains to align.

What Stays the Same

It is important to note that the core architecture of BRCGS — senior management commitment, HACCP-based food safety planning, prerequisite programmes, and a continuous improvement framework — is not expected to change fundamentally. Issue 10 will refine and strengthen these elements, not replace them.

Manufacturers with a well-implemented Issue 9 system are building on a solid foundation. The transition to Issue 10 will be most manageable for sites that genuinely live their food safety management system, rather than treating it as a documentation exercise.

How to Prepare Now

You do not need to wait for Issue 10 to be published to start preparing. Here is what you can do today:

1. Treat food safety culture as a continuous programme. Build measurable objectives, track them consistently, and make culture performance a standing item at management reviews. The more embedded your culture programme is before Issue 10 arrives, the easier the transition will be.

2. Strengthen your environmental monitoring programme. If your EMP is still developing, invest in making it genuinely risk-based — with documented zone rationale, trend analysis, and clear corrective action triggers. Issue 10 will expect more, not less.

3. Review your allergen management programme. Ensure your allergen cleaning procedures are validated, not just documented. If you have not conducted a formal allergen cleaning validation, now is the time to plan one.

4. Assess your supply chain management system. Review your supplier approval programme for completeness and risk-basis. Test your traceability system against faster mass balance expectations. Identify gaps and address them proactively.

5. Monitor BRCGS communications. BRCGS publishes consultation documents, stakeholder updates, and transition guidance through its website and industry channels. Staying connected ensures you will not be caught off guard when Issue 10 details are confirmed.

How Ascent Food Consulting Can Help

Our team works closely with food manufacturers across Canada and the United States to keep their BRCGS systems current, audit-ready, and aligned with the direction of the standard. As Issue 10 details emerge, we will be updating our clients and publishing further guidance.

In the meantime, we can help you assess your current Issue 9 system against anticipated Issue 10 directions, strengthen your food safety culture programme, build a more robust EMP, and develop the supply chain management capabilities the next edition will require.

Contact our team to discuss where your facility stands and how we can help you stay ahead.