New BRCGS requirements for storage and distribution

What's changing for logistics companies in the food and product chain?

Does your company store, tranship or transport food, packaging or consumer products? And is your site certified to the BRCGS Global Standard for Storage and Distribution, Issue 4? If so, additional requirements will apply from 10 August 2026 at your next BRCGS audit.

The changes are published in SD404: Position Statements for Issue 4, version 8.1, issued by BRCGS at the end of May 2026. This document brings together twenty position statements: eleven older clarifications that remain valid, and nine new or amended statements that take effect from 10 August 2026. A position statement is not an optional explanation: once its effective date is reached, it becomes binding, in the same way as a clause in the standard itself. Auditors will therefore assess the new requirements at all relevant audits taking place from 10 August 2026.

Why is the standard changing?

BRCGS has amended the requirements for storage and distribution to align them with the GFSI Benchmarking Requirements 2024. GFSI is an international initiative that sets requirements for recognised food safety standards.

The existing BRCGS standard is not being fully replaced. However, several elements are being clarified and tightened. The emphasis now falls more strongly on three questions:

• Do procedures actually work in practice?
• Do staff have sufficient knowledge to carry out their responsibilities?
• Can the company demonstrate that risks are controlled across the entire logistics chain?

1. Staff must know their responsibilities

It's no longer enough for tasks and instructions to exist on paper. Staff must understand their responsibilities and be able to consult relevant procedures.

This applies not only to permanent staff, but also to:

• temporary staff;
• agency workers;
• contracted personnel.

During an audit, an auditor may question staff on the shop floor, for example about temperature deviations, damaged products, allergens, cleaning or traceability.

The company must be able to demonstrate that staff have not only completed training, but also know how to act in practice.

2. Prerequisites must be a visible part of HACCP or HARA

BRCGS states more clearly that the prerequisites for safe working must be in place before a risk analysis is carried out. These prerequisites are often referred to as prerequisite programmes or PRPs.

For storage and distribution companies, this includes, for example:

• maintenance of buildings, vehicles and equipment;
• safe storage and handling of products;
• control of the cold chain;
• cleaning and disinfection;
• pest control;
• allergen control;
• personal hygiene;
• handling of damage, waste and returns;
• approval of suppliers and subcontractors;
• training and instruction of staff.

The key change is that these programmes must demonstrably link to the HARA or HACCP analysis. The company must be able to explain which risks are controlled by the prerequisites and how it is verified that the measures work effectively.

Not every measure needs to be formally validated. Where validation is relevant, you must verify that it works and review the measure periodically.

3. Clearer contracts with service providers and subcontractors

Companies must record their agreements with external service providers and subcontractors more precisely.

Contracts or specifications must clearly state:

• which service is provided;
• which product safety risks are involved;
• which storage and transport conditions apply;
• which temperature limits must be maintained;
• how products must be protected;
• which products must be kept separate from one another;
• which type of vehicle or equipment is required;
• how traceability is ensured.

Where relevant, chemical, microbiological, physical and allergen requirements must also be included. Food safety criteria must be based on appropriate scientific principles.

Subcontractors must work to at least the same standard as the BRCGS-certified site. Additional requirements from customers or brand owners must also be incorporated into the agreements.

4. Greater attention to food fraud expertise

Companies that store or distribute products must assess how vulnerable their activities are to food fraud, for example counterfeit products, deliberate substitution or trading in products of unreliable origin.

The person or team carrying out this assessment must demonstrate knowledge of:

• the principles of food fraud;
• methods for risk and vulnerability assessment;
• the products involved;
• the supplier and distribution chain;
• relevant market developments.

BRCGS does not require everyone to complete a specific external course. Expertise can also come from internal training, experience and the quality of the assessment carried out.

A multidisciplinary team can be valuable here. Quality assurance knows the assessment method, purchasing spots unusual prices or delivery issues, and goods receiving knows what actually comes in.

5. Greater attention to internal and external threats

The assessment of product security, often referred to as product defence, is also being tightened.

The threat assessment must cover both internal and external threats, such as:

• deliberate contamination;
• sabotage;
• unauthorised access;
• theft or tampering;
• misuse by own or contracted staff;
• risks during storage and transport.

The assessment must be reviewed at least annually. An additional review is required whenever a new threat becomes known or a product security incident occurs.

Responsible staff must know the principles of product defence and understand which risks are linked to the site, products and logistics activities.

6. Safe storage of equipment

BRCGS no longer looks only at the design and use of equipment. Its condition and storage must also prevent products from being damaged or contaminated.

Equipment must therefore:

• be suitable for its intended use;
• be capable of being cleaned properly;
• be in good condition;
• be stored clean and protected;
• not provide a harbourage for pests.

For movable equipment, it may be necessary to restrict its use to certain zones. This prevents equipment from transferring contamination from one environment to another.

7. Clearer requirements for cleaning equipment

Cleaning equipment is also receiving extra attention.

Cleaning tools must:

• be hygienically designed;
• be suitable for their intended purpose;
• not shed fibres or other materials;
• be identifiable for their intended use;
• be cleaned after use;
• be stored hygienically and off the floor.

A company could, for example, use colour coding to indicate which tool may be used in which area. BRCGS does not prescribe a specific method, provided the chosen system is clear and effective.

8. Irradiation added to the rules for special processes

The BRCGS standard already includes requirements for activities such as chilling, freezing, tempering, thawing and high-pressure processing of pre-packed products. From 10 August 2026, irradiation will also be explicitly added to this section.

Companies carrying out such a process must work to the product owner's specifications. Relevant process parameters, such as temperature, pressure or radiation dose, must be monitored.

Automatic alarm systems are required or, where appropriate, sufficiently frequent manual checks.

Companies that do not carry out irradiation themselves would do well to check whether an outsourced service provider does so.

These 11 older statements also remain in force

Alongside the nine new clarifications, SD404 version 8.1 also brings together eleven previously published statements that remain in effect. A brief overview for reference:

• Trimming fresh fruit or vegetables for aesthetic reasons is only permitted under a concession, and only for sites still certified to Issue 3.
• Sites with a transport-only scope may now use the BRCGS S&D logo.
• For wholesale own-brand products, a new fraud control section applies, with a mandatory supplier vulnerability assessment plan.
• The rules on sanitary facilities and hairnets during open product handling have been clarified and made risk-based.
• Switching to a different certification body for an early recertification audit is only permitted with prior BRCGS approval.
• The unannounced audit window has been reduced from 9 to 4 months, and the number of non-audit days from 15 to 10.
• Certificate validity has been shortened: from 18 to 12 months for grade AA-B, and from 12 to 6 months for grade C-D.
• A separate points system for non-conformities applies to the Cross-Docking module.
• The site's responsibility to enable an unannounced audit within the window has been clarified.
• Specific rules apply to changing certification body outside the 4-month window.
• An "initial audit" has been redefined as the first audit at a site, or an audit following a break of more than 24 months.

What do you need to arrange before 10 August 2026?

BRCGS-certified storage and distribution companies can prepare using the following steps:

• Determine which new requirements apply to your site.
• Compare the requirements against existing procedures and working practices.
• Interview staff to check that they understand their responsibilities.
• Demonstrably link the prerequisites to the HARA or HACCP analysis.
• Check contracts with suppliers, service providers and subcontractors.
• Record the expertise of the teams responsible for food fraud and product defence.
• Inspect equipment and cleaning tools for suitability, identification and storage.
• Check special processes, including any outsourced irradiation.
• Keep records of process parameters for at least the shelf life of the product plus one year, so they can support a due diligence defence if required.
• Record, for each requirement, which documents, records and practical situations can demonstrate compliance during the audit.

Not just a paperwork exercise

These changes require more than updating a manual. The auditor will want to establish whether the measures actually work.

The key question therefore becomes: can the organisation demonstrate that staff, procedures, contracts and day-to-day work together ensure safe storage and distribution?

Companies that get this right before 10 August 2026 will reduce their audit risk and, at the same time, strengthen control over their logistics processes.

Source: BRCGS, official amendments to the Global Standard Storage and Distribution Issue 4.

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