BRCGS Issue 9 in 2026: How US Importers Should Use a Supplier’s Certificate in Their FSVP

Introduction

For many US importers, a foreign supplier’s BRCGS certificate is the first document in the supplier file. It is a strong signal: Issue 9 of the BRCGS Global Standard Food Safety is GFSI-benchmarked, and BRCGS said in January 2026 that the Standard has more than 24,500 certificated sites in 137 countries. But a certificate is not a Foreign Supplier Verification Program (FSVP). FDA expects the importer to decide what verification is appropriate, obtain the right evidence, and document its own review of that evidence.

2026 is also a year of change around the Standard. A new version of BRCGS’s Issue 9 position statements took effect on 10 August 2026, adding a protective footwear requirement, and work on Issue 10 is under way. This guide explains what US Technical and Quality Managers should check on a BRCGS certificate and audit report, how that evidence fits 21 CFR 1.506, and what to watch as Issue 10 develops. It complements our checklist of what an FSVP evidence pack should contain.

Where Issue 9 Stands in 2026

Issue 9 is still the current standard

BRCGS published Issue 9 in August 2022, and it has applied to all audits conducted from 1 February 2023. There is no Issue 10 audit date yet, so any supplier certificate you receive this year should be against Issue 9.

Position statements updated from 10 August 2026

BRCGS document F926 (version 4, dated 27 April 2026) took effect on 10 August 2026. Its one new requirement, Position Statement 4, comes from aligning Issue 9 with the GFSI Benchmarking Requirements v.2024. Version 4 also makes minor wording changes to three earlier position statements that have applied since 2024. F926 now covers:

• ✔️ Clarified wording on clause 1.1.10, which makes the site responsible for making sure unannounced audits can happen to protocol, including agreeing contract terms with the certification body before the 4-month audit window opens and keeping it informed about shutdowns (in force since 1 August 2024)
• ✔️ A rule that sites may not change certification body in the 4 months before the re-audit due date unless BRCGS agrees in writing (since 1 May 2024)
• ✔️ A clarified definition of an “initial audit” (since 1 January 2024)
• ✔️ New from 10 August 2026: Position Statement 4 amending clause 7.4.2, so protective clothing now includes suitable protective footwear where required to prevent product contamination

Issue 10 is in development

BRCGS ran a public consultation on Issue 9 that closed on 15 February 2026, and its Technical Working Group for Issue 10 was scheduled to hold its first meeting on 1 April 2026 and to run for about 12 to 15 months. BRCGS has not announced a publication or audit start date. Treat any date you see as an estimate, and plan supplier programmes on Issue 9.

Sources: BRCGS F926 Position Statements for Issue 9, v4 | BRCGS Issue 10 Technical Working Group | BRCGS Issue 9 consultation

What a BRCGS Certificate Does and Doesn’t Prove for FSVP

What FSVP asks of the importer

Under 21 CFR 1.506, the importer must determine and document appropriate supplier verification activities, then conduct or obtain documentation of them before importing and periodically afterwards. The options are an onsite audit, sampling and testing, a review of the supplier’s food safety records, or another appropriate activity. Where the supplier controls a hazard with a reasonable probability of serious adverse health consequences or death, the default is an onsite audit before first import and at least annually, unless you make an adequate written determination that something else is appropriate (§ 1.506(d)(2)).

Where a BRCGS audit can help

If your documented determination under § 1.506(d) is that an onsite audit is the right verification activity, you may rely on an audit carried out by another entity, such as a BRCGS audit, provided you review and assess its results (§ 1.506(e)(2)). It is the full audit report, not the certificate, that can support that verification, and only if the audit meets the onsite audit conditions in § 1.506(e)(1)(i):

• ✔️ The audit was performed by a qualified auditor, meaning a qualified individual who can read the records reviewed and has the technical expertise, through education, training or experience, to perform the audit (§§ 1.500 and 1.503(b))
• ✔️ Where the food is subject to FDA food safety regulations, the audit considered those regulations and reviewed the supplier’s written food safety plan and its implementation for the hazard being controlled
• ✔️ You hold or can obtain the audit procedures, dates, conclusions, corrective actions for significant deficiencies, and evidence the auditor was qualified
• ✔️ There is no financial conflict of interest influencing the result, and payment was not tied to the outcome (§ 1.506(e)(4))

The second point is the usual gap. A standard Issue 9 audit assesses the BRCGS requirements. It does not automatically assess the supplier against FDA’s preventive controls or produce safety rules. Ask the supplier whether any FDA-specific module or additional assessment was included, and if not, decide what extra evidence you need.

Your review is the FSVP record

§ 1.506(e)(3) requires you to promptly review and assess the results of verification activities and document that review. If the results do not give adequate assurance that the hazards are significantly minimised or prevented, you must take corrective action under § 1.508. On its own, a GFSI-benchmarked certificate does not satisfy FSVP supplier verification. A certificate filed without a dated, signed review (§ 1.510(a)(2)) is evidence the supplier was audited, not evidence that you verified the supplier.

How to Read a Supplier’s BRCGS Evidence

1. Check status in the BRCGS Directory

The public BRCGS Directory lists sites that are currently certificated. Expired, suspended or withdrawn sites are not listed, and sites can also choose to be removed from the public listing. BRCGS states that documents obtained from the Directory rather than from the supplier can be treated as complete, contemporary and authenticated. Ask the supplier to share the full audit report with you through the Directory.

2. Match the scope to what you buy

Compare the certificate’s scope, products and site address with the item, the manufacturing site on your purchase order and the facility named on your prior notice. A valid certificate for a different site or product category gives you nothing for this food.

3. Look past the grade

Issue 9 audits are graded from AA to D, with a “+” for unannounced audits. The grade reflects the number and severity of non-conformities. For FSVP, the content matters more: which clauses had non-conformities, whether any relate to a hazard you rely on the supplier to control, and whether corrective actions were closed with evidence.

4. Note the audit programme and due date

Sites on announced or blended programmes must have at least one unannounced audit every 3 years. The certification body tells the site which year, but not the date. Unannounced audits fall in the 4 months before the audit due date. Record the due date so you request the new report when it is issued, rather than discovering an expired certificate at entry.

5. Set a re-verification trigger

Link each certificate to the foods it supports in your FSVP and to a review date. Re-assess when the grade drops, scope changes, the site changes certification body, or a recall, import alert or customer complaint involves the supplier.

What Changes for Your Supplier Programme in 2026

• ✔️ Ask about unannounced readiness. Under clause 1.1.10 as clarified in F926, a site that has not made arrangements with its certification body before the 4-month audit window opens receives a major non-conformity, and its certificate may expire. That can become your supply problem.
• ✔️ Update your supplier questionnaire. Add the Issue 9 version, audit programme type, next due date and whether the most recent audit took place after F926 version 4 took effect on 10 August 2026.
• ✔️ Separate certificate tracking from FSVP review. Certificate expiry is a document-control task. Assessing whether the audit addresses FDA hazards is a qualified-individual task.
• ✔️ Watch Issue 10 without re-planning yet. Note the consultation themes, but keep supplier contracts and FSVPs referencing the standard and edition actually audited.

Turning Certificates Into Verified Supplier Evidence

Most importers already hold the certificates. What is usually missing is the link between each certificate, the hazards it addresses, the importer’s dated review, and the reminder to request the next report. When that link lives in spreadsheets and email threads, FSVP files look complete until FDA asks how the evidence was assessed.

Primority helps Technical and Quality teams keep supplier evidence current and reviewable.

• ✔️ Structured supplier document control, so certificates and audit reports sit with the foods they support
• ✔️ Clear ownership for reviews, corrective actions and renewal dates
• ✔️ Support from food safety practitioners who work with importer and manufacturer programmes

Don’t let a supplier’s certificate stand in for your verification. Book a personalized demo to see how Primority can support your supplier compliance programme.

This article is for informational purposes only and does not constitute legal advice. Confirm your obligations against the current text of 21 CFR Part 1, Subpart L (including §§ 1.500, 1.506 and 1.508) and current BRCGS documents, including F926 and the Issue 9 Standard, and with your regulatory counsel. Primority is not affiliated with BRCGS, GFSI or FDA. Issue 10 timing has not been announced by BRCGS; always check brcgs.com for the latest position.