Top 10 BRCGS Non-Conformities (2026) and How to Fix Them

Josh Clauser

Josh Clauser leads website, content, and SEO strategy at Kiwa ASI, where he specializes in food safety certification, compliance, and auditing across SQF, BRCGS, FSSC 22000, and other GFSI standards. A passionate educator, Josh also develops the company's food safety courses and built the learning management system used to deliver them. He holds a BS in Dietetics and an MA in FCS/Nutrition from Ball State University, and previously taught Community Nutrition at the University of Connecticut.

Published Oct 1, 2026, 2:33:13 PM

Most BRCGS Food Safety non-conformities are found on the factory floor, not in the paperwork. In BRCGS's own data for 2024-25, all five of the most-cited Issue 9 clauses sat in Section 4, Site Standards, led by premises and equipment hygiene with 4,715 non-conformities. Here are the ten findings that come up most, what auditors look for, and the evidence that closes each one.

At a glance

BRCGS Non-Conformities at a Glance

A non-conformity is a requirement of the BRCGS Global Standard Food Safety that a site doesn't fully meet at the audit. The number and severity of non-conformities set your grade, how often you are audited, and whether you are certificated at all.^[1] The same few clauses account for a large share of findings year after year: in 2021, BRCGS found that 5.6% of the clauses in the Food Standard produced 30% of all non-conformities raised.^[2]

4,715Non-conformities raised against clause 4.11.1 (hygiene) in 2024-25BRCGS Annual Report 2024-25
7 of 8Most common findings that sit in Section 4, Site StandardsLRQA 2025-26 datasheet
28 daysTo submit corrective action, root cause and a preventive action planIssue 9 Part III
5Minor non-conformities or fewer, with no majors, for an AA gradeIssue 9 Part III, Table 2

Key takeaways

The top five Issue 9 findings in 2024-25 were hygiene (4.11.1), equipment design (4.6.2), chemical control (4.9.1.1), doors (4.4.8) and walls (4.4.1). All are visible on a plant walk.
Most of these findings come from slipping routines, not missing systems: cleaning, maintenance and checks that drift between audits.
Six of the ten sit under fundamental clauses. A major against the intent of a fundamental clause means no certificate.
Every non-conformity needs a correction, a root cause and a preventive action plan within 28 days, or the site isn't certificated.

Updated October 1, 2026. Based on BRCGS Food Safety Issue 9 and the position statements in force from August 10, 2026.

Definitions

What Counts as a BRCGS Non-Conformity?

BRCGS uses three levels of non-conformity: critical, major and minor. A critical non-conformity stops certification on its own. Majors and minors are counted to set the grade, and every one of them needs a documented correction, root cause and preventive action plan.^[1]

BRCGS non-conformity levels
Level	What it means	What happens
Critical	A critical failure to comply with a food safety or legal issue.	No certificate. An existing certificate is withdrawn, and a new full audit can't happen sooner than 28 days later.
Major	A substantial failure to meet a statement of intent or any clause, or evidence that raises significant doubt about the product.	Counts toward the grade. Against the statement of intent of a fundamental clause, it means no certificate.
Minor	A clause isn't fully met, but the product's conformity isn't in doubt.	Counts toward the grade. Repeated minors against one clause can be raised as a single major.

Paraphrased from Issue 9 Part III, section 2.3. Auditors can't cluster many minors into one minor, and a certification body must justify more than 20 minors raised with one or no majors.

Grades

How Do Non-Conformities Set Your Grade?

Your grade comes from the number and level of non-conformities, and it sets how often you're audited. Grades AA, A and B mean an audit every 12 months; C and D mean every six months. Unannounced audits add a plus sign, from AA+ to D+.^[1]

BRCGS Issue 9 grading
Grade	Majors	Minors	To close	Audit every
AA (AA+)	None	5 or fewer	Evidence within 28 days	12 months
A (A+)	None	6 to 10	Evidence within 28 days	12 months
B (B+)	None, or 1	11 to 16, or 10 or fewer with 1 major	Evidence within 28 days	12 months
C (C+)	None, 1 or 2	17 to 24; 11 to 16 with 1 major; 10 or fewer with 2 majors	Evidence within 28 days; revisit if 2 majors	6 months
D (D+)	None, 1 or 2	25 to 30; 17 to 24 with 1 major; 11 to 16 with 2 majors	Revisit within 28 days	6 months
Not certificated	Any critical, or 3+ majors	31+ minors; 25+ with 1 major; 17+ with 2 majors	A new full audit	Not applicable

From Issue 9 Part III, Table 2. A major against the statement of intent of a fundamental clause also means no certificate, whatever the count.

The certification decision, and the certificate if one is granted, must follow within 42 calendar days of the audit.^[1]

The top 10

The 10 Most Common BRCGS Non-Conformities

Items 1 to 5 are BRCGS's own top five Food Safety non-conformities for 2024-25, in order, with the number raised.^[3] Items 6 to 10 come up repeatedly in BRCGS's 2021 top 10 and in LRQA's 2025-26 analysis of more than 72,000 audits.^[2]^[4] Neither source counts those five on the same scale, so they are listed by section, not ranked.

Clause requirements are summarized from Issue 9 Part II.^[5] U.S. overlaps are from 21 CFR Part 117.^[6]

Premises and equipment hygiene

4.11.1
Fundamental (4.11)
4,715 in 2024-25

What the clause asks: Premises and equipment must be kept clean and hygienic. It is the short clause behind the long cleaning program.
What auditors write up: Build-up in hard-to-reach places: under and behind equipment, overheads, drains and frames. Areas missed by the schedule, residues from the last run, and cleaning that varies from shift to shift.
Evidence that closes it: Photos of the area after cleaning, the cleaning schedule updated to include it, a verification record, and a root cause such as an area that needs dismantling or a shift short of staff.
How to prevent it: Map hard-to-reach areas into the master cleaning schedule

Check overheads, frames and drains in pre-start inspections

Use a clean-as-you-go rule between scheduled cleans

Trend findings from your own hygiene inspections
U.S. overlap: 21 CFR 117.35(a): buildings, fixtures and facilities kept clean and in good repair.

Equipment design and construction based on risk

4.6.2
3,322 in 2024-25

What the clause asks: Equipment must be designed and built, on the basis of risk, to prevent contamination: suitable seals, impervious surfaces, smooth welds and joints, and food-contact parts that are suitable and legal.
What auditors write up: No risk-based design review for new or modified equipment, weak commissioning, and unhygienic features such as exposed threads, damaged seals or porous materials where product can collect.
Evidence that closes it: A hygienic design assessment for the equipment, the repair or modification record, food-contact suitability documents, and a commissioning and hygiene clearance record.
How to prevent it: Put hygienic design into every equipment purchase specification (4.6.1)

Use the commissioning and hygiene clearance procedure (4.6.3) for new and second-hand equipment

Include seals, welds and fixings in maintenance inspections
U.S. overlap: 21 CFR 117.40(a) and (b): equipment adequately cleanable, maintained, and with smoothly bonded seams.

Chemical control

4.9.1.1
3,284 in 2024-25

What the clause asks: Non-food chemicals need an approved list, safety data sheets, confirmed suitability for food plants, labels on every container, restricted storage separate from ingredient chemicals, trained users, spill procedures and safe disposal.
What auditors write up: Unlocked or unrestricted chemical storage, decanted spray bottles with no label, chemicals stored close to production, and products in use that aren't on the approved list. LRQA counted more than 10,000 findings against this clause.
Evidence that closes it: Photos of locked, labeled storage, the updated approved list, labeled secondary containers, and training records for the people who handle chemicals.
How to prevent it: Label every decanted container at the point of filling

Lock chemical stores and limit keys to trained staff

Reconcile the approved list with what purchasing actually buys

Add chemical storage to daily GMP checks
U.S. overlap: 21 CFR 117.35(b): cleaning compounds safe for use; toxic materials identified, held and stored to protect food.

Doors

4.4.8
3,007 in 2024-25

What the clause asks: Internal and external doors must be kept in good condition. External doors and dock levelers must fit closely or be proofed, and external doors into open-product areas must stay shut during production except in an emergency.
What auditors write up: Doors propped open for airflow or forklift traffic, gaps under doors, damaged dock seals and strip curtains. LRQA's analysis points out that pest problems usually start at an access point, not with an infestation.
Evidence that closes it: Repair invoices or photos, a door-closed rule built into GMP checks, and proofing added where gaps were found.
How to prevent it: Check door seals and gaps on a set schedule

Fit self-closers or alarms on doors that tend to be left open

Give forklift routes a door solution that doesn't rely on propping
U.S. overlap: 21 CFR 117.35(c): effective measures to exclude pests from production and storage areas.

Walls, floors and ceilings

4.4.1
4.4.2
4.4.4
2,933 in 2024-25 (walls)

What the clause asks: Walls must be finished and maintained to prevent dirt build-up, limit condensation and mould, and allow cleaning. Floors must be hard-wearing, impervious and in good repair, and ceilings and overheads must not present a contamination risk.
What auditors write up: Damaged or holed wall panels, flaking paint, condensation and mould on ceilings, cracked floors where water pools, and temporary repairs that became permanent.
Evidence that closes it: Maintenance work orders and photos of the repair, a condensation control plan where needed, and a record of any temporary repair with a date for the permanent fix.
How to prevent it: Run a fabric survey of every production room each quarter

Prioritize repairs above open product

Track temporary repairs with a deadline
U.S. overlap: 21 CFR 117.20(b)(4): floors, walls and ceilings cleanable, kept clean and in good repair; drip and condensate controlled.

Identification of materials for traceability

3.9.2
Fundamental (3.9)

What the clause asks: Raw materials and primary packaging, work in progress, part-used materials, finished products and materials on hold must all be identified well enough to keep traceability.
What auditors write up: Part-used ingredient bags with no label, unmarked work-in-progress tubs, rework without identification, and held product with unclear status. LRQA notes that traceability usually breaks down on the floor, not in the written procedure.
Evidence that closes it: A labeling rule for part-used and in-process materials, photos of the corrected labels, and a traceability test showing the materials can be traced.
How to prevent it: Label at the moment a container is opened or filled

Tag work in progress and rework with lot and date

Test traceability at least yearly; Issue 9 expects results within four hours (3.9.3)
U.S. overlap: No single 21 CFR 117 equivalent, but a written recall plan (117.139) only works if materials can be traced.

Cleaning procedures and verification

4.11.2
4.11.3
Fundamental (4.11)

What the clause asks: Cleaning procedures must state who cleans what, how often, by what method (including dismantling), with which chemicals and concentrations, and how it is recorded and verified. Limits for acceptable cleaning must be defined, with corrective action when results fall outside them.
What auditors write up: Procedures missing concentrations or dismantling steps, no defined pass or fail limits, ATP or swab results with no follow-up, and records that are signed but never verified.
Evidence that closes it: Revised procedures with the missing details, defined limits (visual, ATP, microbiological or allergen as the risk requires), and records showing corrective action when limits are missed.
How to prevent it: Write limits into each procedure, not a separate file

Verify a sample of cleaning records every week

Validate cleaning that controls a specific hazard, such as allergen changeovers
U.S. overlap: 21 CFR 117.35(d): food-contact surfaces cleaned as often as needed to protect against contamination and allergen cross-contact.

HACCP flow diagrams and hazard identification

2.5.1
2.6.1
2.7.1
Fundamental (2)

What the clause asks: Flow diagrams must cover every product or process from receipt to dispatch and be verified on site at least yearly. Hazard identification must cover microbiological, physical, chemical and radiological hazards, fraud, malicious contamination and allergens at every step.
What auditors write up: Flow diagrams missing rework, utilities or packaging steps, no record of an annual on-site check, and hazard lists that skip a hazard type such as allergens or fraud. LRQA notes these are usually gaps in mapping, not in method.
Evidence that closes it: Updated and verified flow diagrams, a hazard analysis covering every hazard type, and HACCP team minutes showing the review.
How to prevent it: Walk each flow diagram on the floor once a year and sign it

Use a hazard checklist that lists every hazard type

Trigger a HACCP review for every process or product change
U.S. overlap: 21 CFR 117.130: a written hazard analysis for each type of food, including hazards introduced for economic gain.

Internal audit programme

3.4.1
Fundamental (3.4)

What the clause asks: Internal audits must run on a schedule with at least four audit dates spread through the year, with risk-based frequency, and cover every food safety and quality activity at least once a year, including HACCP, prerequisite programs, food defense and fraud plans.
What auditors write up: Fewer than four audit dates, activities left out of the scope, one audit that tries to cover everything, and findings closed without checking the fix worked.
Evidence that closes it: A revised schedule with four or more dates and full scope, audit reports with objective evidence, and verification that corrective actions were completed (3.4.3).
How to prevent it: Plan the year's audits by activity and risk, not by date alone

Give each audit a defined scope

Make sure no one audits their own work (3.4.2)
U.S. overlap: No direct 21 CFR 117 equivalent.

Food safety and quality culture plan

1.1.2
Fundamental (1.1)

What the clause asks: Senior management must keep a plan to develop and improve food safety and quality culture, with activities covering communication, training, employee feedback, required behaviors and performance measurement, an action plan with timescales, and a review of what worked. The plan is reviewed at least yearly.
What auditors write up: Plans that list intentions with no activities, timescales or measures, and no review of last year's actions. LRQA notes these gaps reflect incomplete plans, not a lack of intent.
Evidence that closes it: A complete plan against every element of the clause, evidence that the activities happened, and a dated review of their effectiveness.
How to prevent it: Set measurable culture objectives and track them

Collect employee feedback in more than one way

Review the plan in management review every year
U.S. overlap: No direct 21 CFR 117 equivalent.

Also worth checking

Other recurring BRCGS findings
Clause	Where it shows up	What it asks
4.15.1 Storage	In BRCGS's 2021 top 10	Storage procedures based on risk: segregation, off-floor and off-wall storage, temperature transfers
3.2.1 Document control	Recurring in LRQA's 2025-26 data	A controlled list with current versions, authorization and a record of changes
7.4 Protective clothing	Recurring in LRQA's 2025-26 data	Clothing rules and supply; footwear and beard snoods now explicit in 7.4.2

August 2026

What Changed for BRCGS Audits on August 10, 2026?

For Food Safety sites, the position statement that took effect on August 10, 2026 changes one clause: 7.4.2 now requires protective clothing to include snoods for beards and moustaches and suitable protective footwear, where needed to prevent contamination. It came from aligning the Standard with GFSI's 2024 benchmarking requirements.^[7]^[8]

Other changes in the same round apply to Agents and Brokers, Storage and Distribution, and Packaging Materials, not to Food Safety audits.^[8]

Non-conformities that come from scheduling, not the plant

Avoidable protocol non-conformities
What happens	Result
An announced audit delayed past the due date	Major non-conformity at the next audit, unless the delay is justified under the protocol^[1]
No arrangements in place before the 4-month unannounced window opens	Major non-conformity, and the due date moves, so the certificate may expire^[7]
Changing certification body in the last 4 months before the due date	Not permitted without written BRCGS agreement^[7]
Refusing the auditor entry at an unannounced audit	Certificate suspended until a new unannounced audit is completed^[1]

U.S. angle

Where Do BRCGS Findings Overlap FDA Rules?

Most of the top BRCGS findings map directly onto FDA's current good manufacturing practice rules in 21 CFR Part 117, Subpart B. Fixing them for your BRCGS audit also puts you in a better position for an FDA inspection.^[6]

Where BRCGS findings overlap 21 CFR Part 117
BRCGS clause	21 CFR 117	What FDA requires
4.11.1 Housekeeping and hygiene	117.35(a) General maintenance	Buildings and fixtures clean and in repair
4.11.2 Cleaning procedures	117.35(d) Sanitation of food-contact surfaces	Surfaces cleaned often enough to prevent contamination and cross-contact
4.6.2 Equipment design	117.40 Equipment and utensils	Cleanable design and materials; smoothly bonded seams
4.9.1.1 Chemical control	117.35(b) Cleaning compounds and toxic materials	Safe compounds; toxic materials identified and stored away from food
4.4.1 to 4.4.4 Building fabric	117.20(b)(4) Plant construction	Floors, walls and ceilings cleanable and in good repair; condensate controlled
4.4.8 Doors	117.35(c) Pest control	Effective measures to keep pests out
7.4 Protective clothing	117.10(b)(1) Personnel cleanliness	Outer garments suitable to the operation
2.7.1 Hazard identification	117.130 Hazard analysis	A written hazard analysis for each type of food
4.15.1 Storage	117.93 Warehousing and distribution	Storage that protects against contamination and deterioration

Corrective action

How Do You Close a Non-Conformity Within 28 Days?

For every non-conformity, a site has 28 calendar days after the audit to send the certification body evidence of the correction, the root cause and a preventive action plan with timescales. Without all three, the site isn't certificated and needs a new full audit.^[1]

Correct the issueFix what the auditor saw: clean the area, repair the door, label the container.Days 1 to 7
Find the root causeAsk why the system allowed it, not just what went wrong. A missed area on the schedule is a cause; “operator error” rarely is.Days 1 to 14
Plan the preventive actionSet the change that stops it happening again, with an owner and a date.Days 7 to 21
Send the evidenceUpdated procedures, records, photos or invoices, plus the root cause and plan.By day 28
Expect a revisit if neededA C grade with two majors, or any D grade, needs a site visit or remote assessment within 28 days.Within 28 days
Show it workedAt the next audit, the auditor checks that the corrective and preventive actions are in place and working.Next audit

For a step-by-step method, see our guide to root cause analysis, and the GFSI non-conformance case studies for worked examples.

Issue 10

Is BRCGS Issue 10 Out Yet?

Not yet. As of October 1, 2026, BRCGS hasn't announced a publication date for Food Safety Issue 10. The public consultation on Issue 9 ran from January 9 to February 15, 2026, and the technical working group that drafts Issue 10 first met on April 1, 2026, for work planned to take about 12 to 15 months.^[9]^[10]

BRCGS typically allows about six months between publishing a new issue and the first audits against it.^[11] Until then, audits are to Issue 9 plus the position statements in force.

Support

How Kiwa ASI Can Help

Kiwa ASI delivers BRCGS certification audits in the United States as a listed office of Kiwa's BRCGS-approved certification bodies, Kiwa Agri Food (UKAS-accredited) and Kiwa España (ENAC-accredited). Our U.S. auditors work to Issue 9 and the current position statements. See BRCGS certification for the audit process, grades and audit options.

To find these findings before your auditor does, our BRCGS internal auditor training and principles of internal auditing courses build the internal audit program that clause 3.4.1 requires. Training is offered through ASI Training and Consulting, LLC, separately from certification, and has no effect on audit outcomes.

FAQ

Frequently Asked Questions

What is the most common BRCGS non-conformity?

Premises and equipment hygiene, clause 4.11.1. BRCGS recorded 4,715 non-conformities against it in 2024-25, more than any other Issue 9 clause, and it was also the top finding in BRCGS's 2021 data and LRQA's 2025-26 analysis.

What is the difference between a major and a minor non-conformity?

A minor means a clause isn't fully met but the product isn't in doubt. A major is a substantial failure against a clause or its statement of intent, or evidence that raises significant doubt about the product. Majors weigh more in the grade, and a major against a fundamental clause's statement of intent means no certificate.

How many minor non-conformities can you have and still be certified?

Up to 30 minors with no majors still earns a certificate, at grade D, with a revisit and six-monthly audits. An AA grade allows five minors or fewer. Thirty-one or more minors, or any critical, means no certificate.

What happens if you get a critical non-conformity?

The site isn't certificated, and an existing certificate is withdrawn. The site needs a new full audit, which can't happen sooner than 28 days later, and some customers must be told straight away.

How long do you have to close BRCGS non-conformities?

28 calendar days from the audit to send evidence of the correction, the root cause and a preventive action plan. A C grade with two majors, or any D grade, also needs a revisit within 28 days.

Does a C grade mean six-month audits?

Yes. Grades C and D, and C+ and D+, mean the next audit is due in six months. Grades AA, A and B mean 12 months.

Is BRCGS Issue 10 out?

No. As of October 1, 2026, Issue 10 is still being drafted and BRCGS hasn't announced a publication date. Audits are to Issue 9 and the position statements in force, including the August 10, 2026 change to protective clothing.

Get ready for your BRCGS audit

Talk to our team about BRCGS certification audits delivered by U.S.-based auditors, or train your internal auditors to find these issues first.

Request a BRCGS audit quote BRCGS certification

Training is offered through ASI Training and Consulting, LLC, separately from certification, and has no effect on audit outcomes. Questions? Email US.Info@kiwa-asi.com or call 1 (800) 477-0778.

Keep reading

Sources

BRCGS. Global Standard Food Safety, Issue 9, Part III: Audit Protocol (Issue 9 text published for the Issue 10 consultation). brcgs.com (Word)
BRCGS. Compliance Report 2022, “BRCGS Food Standard: Top 10 non-conformances raised during 2021”. brcgs.com (PDF)
BRCGS. Annual Report 2024-25, “Top five non-conformities of 2024-25” (p. 14) and “2024-25 at a glance” (p. 7). brcgs.com (PDF)
LRQA. Top BRCGS Food Safety Non-Conformities 2025-2026: What the Data Is Telling Us (datasheet, 72,000+ audits analysed). lrqa.com (PDF)
BRCGS. Global Standard Food Safety, Issue 9, Part II: Requirements (Issue 9 text published for the Issue 10 consultation). brcgs.com (Word)
U.S. FDA. 21 CFR Part 117, Subparts B and C (current good manufacturing practice; hazard analysis). ecfr.gov
BRCGS. F926: Position Statements for Issue 9, version 4 (effective August 10, 2026). brcgs.com (PDF)
BRCGS. Key Changes: Position Statements (May 22, 2026). brcgs.com (PDF)
BRCGS. Public consultation now closed: Global Standard Food Safety, Issue 9 (January 9, 2026). brcgs.com
BRCGS. Join the Technical Working Group for Food Safety, Issue 10 (January 9, 2026). brcgs.com
BRCGS. 30 years of safer food (June 25, 2026). brcgs.com