SQF and BRCGS Certification for Confectionery & Chocolate

Choose a program your customers accept, because each customer decides which programs it takes. Both are GFSI-recognized, and both cover Salmonella, allergens, foreign matter, labeling, food defense and food fraud. They differ in how results are reported and who issues the certificate. SQF scores each audit out of 100, with a recertification audit every 12 months. BRCGS grades each audit from AA to D, with an audit every 12 months for AA, A and B and every 6 months for C and D. Through Kiwa, SQF certificates come from Kiwa ASI, and BRCGS audits are delivered through Kiwa's BRCGS-approved certification bodies.

SQF FSC 17 and BRCGS product category 16. In SQF, candy and chocolate fall under FSC 17: Confectionary Manufacturing (SQF's spelling), which extends to all chocolate and imitation chocolate-based processing, under the SQF Food Safety Code: Food Manufacturing. In BRCGS, category 16: Confectionery covers sugar confectionery, chocolate, gums and jellies, and other sweets.

It's the older name for certification to an SQF Food Safety Code, which for these sites is the SQF Food Safety Code: Food Manufacturing. SQF's three programs, the SQF Fundamentals Program, the SQF Food Safety Codes and the SQF Quality Code, were historically known as Levels 1, 2 and 3, and GFSI's list of recognized programs still labels the Edition 9 food safety codes "level 2." The SQF Quality Code, once Level 3, is optional.

No law requires either one. Confectionery and chocolate makers must meet FDA's rules, including facility registration, good manufacturing practices, preventive controls unless exempt, and labeling, whether or not they're certified. Certification is voluntary, though retailers, brand owners and other buyers may ask for GFSI-recognized certification.

First-year cost can range from about $6,000 for a small, well-prepared site to $25,000 or more for a larger plant that needs outside help and upgrades. These are estimates only; your audit fee depends on the audit duration your certification body calculates. The first-year total includes the audit fee (roughly $4,500–$9,000+), SQFI registration ($650 for the Food Manufacturing code, capped at $800 for two or more codes), training, any outside help and any facility upgrades.

Plan on at least four to five months from the day your system starts producing records, and longer if you're building it from scratch. SQFI recommends at least 90 days of records before the certification audit, the audit takes at least two days, non-conformances must be closed within 30 days, and SQF gives the certification body up to 45 days after the audit to make its certification decision. The biggest variables are whether a HACCP plan and environmental monitoring program already exist.

70 out of 100 under Edition 9, with no non-conformances left outstanding. Every audit starts at 100 points; each minor non-conformance deducts 1 point, each major 5 and each critical 50. A score of 70–85 (C – Complies) adds a six-month surveillance audit, and a score below 70 or any critical non-conformance fails an initial audit.

Every 12 months. Recertification audits fall within 30 days either side of the anniversary of the last day of your initial certification audit. Sites rated C – Complies (70–85) under Edition 9 also get a surveillance audit at six months, and at least one recertification audit every three years is unannounced and fully on-site.

Edition 9, for now. SQF audits use Edition 9 until Edition 10 audits begin, which SQFI says will be no earlier than January 2, 2027, depending on GFSI benchmarking. GFSI opened its public consultation on Edition 10 on September 29, 2026. A single audit won't mix requirements from both editions, and a surveillance audit that follows an Edition 9 audit stays on Edition 9, even if it falls after Edition 10 audits begin. Kiwa ASI's ANAB accreditation currently covers specific SQF Edition 9 codes, so ask which edition your first audit will use, and about our Edition 10 status, when you request a quote.

Yes, if we can meet SQF's auditor registration rule for your food sector categories, which we check before we quote. Under Edition 9, you can change to another SQFI-licensed certification body after one certification cycle (the annual period between certification audits), once all non-conformances are closed, as long as the certificate isn't suspended or under threat of suspension or withdrawal. If a surveillance audit is due, change after it. Your certification number, recertification date and unannounced audit schedule carry over, and your current certificate stays valid until it expires. Once Edition 10 applies (no earlier than January 2, 2027), you can switch after your certificate is issued and before your next audit window opens. Kiwa ASI's ANAB accreditation currently covers specific SQF Edition 9 codes, so ask us about Edition 10 status before you plan an Edition 10 transfer. Send your current certificate and your last recertification and surveillance audit reports.

By the number and severity of non-conformities. AA allows 5 or fewer minors; A 6–10; B 11–16, or 1 major and up to 10 minors; C and D allow more minors or up to two majors. AA, A and B sites are audited every 12 months, C and D sites every 6 months, and unannounced audits earn the same grades with a plus, such as AA+. A critical non-conformity, a major against a fundamental requirement or three or more majors means no certificate.

If it makes chocolate from raw cocoa beans, yes. BRCGS names the manufacture of chocolate from raw cocoa beans as an example of a process that needs an ambient high-care area, because a raw material prone to Salmonella goes through a kill step into a ready-to-eat, ambient product. A plant that buys finished chocolate as an ingredient isn't ambient high care for that reason, because the chocolate supplier controlled the risk, but it must still assess its raw materials. BRCGS lists ambient sugar confectionery as an example of a low-risk product.

Kiwa ASI delivers BRCGS audits in the United States as a listed office of Kiwa's BRCGS-approved certification bodies, Kiwa Agri Food (Kiwa Ltd, UKAS-accredited, UK) and Kiwa España SLU (ENAC-accredited). Kiwa ASI's St. Ann, Missouri office is listed in the BRCGS Directory. BRCGS requires auditors to be skilled in the product category they audit, and the certification body checks that, so ask about auditor availability for confectionery when you request a quote. For the standard in full, see our BRCGS certification page.

Yes. They're separate programs with separate audits and certificates, so a site can hold both if different customers ask for different programs.

Yes, but not in the last four months before your re-audit due date unless BRCGS agrees in writing (BRCGS position statement F926). Kiwa ASI delivers BRCGS audits in the United States as a listed office of Kiwa's BRCGS-approved certification bodies, Kiwa Agri Food (Kiwa Ltd, UKAS-accredited, UK) and Kiwa España SLU (ENAC-accredited). Ask about auditor availability for confectionery when you request a quote, and include your current certificate and last audit report.

For SQF, Kiwa ASI is accredited for the code these sites use. ASI Food Safety, LLC (Kiwa ASI) is licensed by SQFI and accredited by ANAB (accreditation ID 1222) to ISO/IEC 17065 for specific SQF Edition 9 codes, including the SQF Food Safety Code: Food Manufacturing, which SQF uses for FSC 17 confectionery. ANAB's listing names codes, not food sector categories, so accreditation alone doesn't confirm we can audit your category. SQF rules require an auditor registered with SQFI for your food sector category, or a registered auditor assisted by an SQFI-approved technical expert. Before we quote, we check whether we can meet that rule and tell you if we can't. For BRCGS, Kiwa ASI is a listed office of Kiwa's BRCGS-approved certification bodies, Kiwa Agri Food (Kiwa Ltd, UKAS-accredited, UK) and Kiwa España SLU (ENAC-accredited).

No. Kiwa ASI audits and issues SQF certificates; it doesn't provide laboratory testing. SQF requires external testing to be done by laboratories accredited to ISO/IEC 17025 or an equivalent standard (2.4.4.2); BRCGS requires analyses critical to product safety, authenticity or legality to be done by accredited labs or labs working to ISO/IEC 17025 principles (5.6.6), and pathogen testing to be outsourced or done in a fully segregated on-site lab (5.6.4). The auditor reviews your results, such as Salmonella, allergen or heavy metal results, as part of the audit.

Edition 10 audits start no earlier than January 2, 2027, depending on GFSI benchmarking. FSC 17 becomes Confectionary and Candy Manufacturing and names gummies. Allergen management (2.8.1) and environmental monitoring (2.4.8) become Core Clauses, where a minor non-conformance deducts 2 points and a major 7, and ratings become Certified (80–100) or Certified with Surveillance (70–79). Kiwa ASI's ANAB accreditation currently covers specific SQF Edition 9 codes, and no Edition 10 code.

FDA's standards of identity in 21 CFR Part 163. Milk chocolate needs at least 10% chocolate liquor, 3.39% milkfat and 12% total milk solids. White chocolate needs at least 20% cacao fat, 14% total milk solids and 3.5% milkfat, and no more than 55% sweetener. Semisweet or bittersweet chocolate needs at least 35% chocolate liquor. Products made with vegetable fats instead of cacao fat carry names such as "sweet chocolate and vegetable fat coating." In SQF, product formulation and specifications fall under 2.3.1 and 2.3.2; in BRCGS, under product design and product authenticity and claims (5.1 and 5.4).

Yes, unless your plant is exempt. FDA's preventive controls rule (21 CFR Part 117, subpart C) requires a written food safety plan prepared or overseen by a preventive controls qualified individual (PCQI). Qualified facilities, such as very small businesses, are exempt from subparts C and G but still follow FDA's good manufacturing practices and file an attestation with FDA. SQF and BRCGS both require HACCP-based food safety plans, but neither certificate replaces FDA's requirements.

Not a binding one. FDA's guidance recommends a maximum of 0.1 parts per million (ppm) lead in candy likely to be eaten often by small children, such as candies made with chili or tamarind. It's guidance, not a regulation, but imported candies from firms on the Red List of Import Alert 99-42 for heavy metals can be detained without physical examination. In SQF, set chemical limits in your specifications (2.3.2.9) and approve suppliers (2.3.4); in BRCGS, through supplier management (3.5.1).

For now. FDA's revocation of Red No. 3 in food takes effect January 15, 2027, and makers have until then to reformulate. California bars food containing it from January 1, 2027, under AB 418. FDA's 2025 plan to eliminate the six other petroleum-based synthetic dyes (Red No. 40, Yellow No. 5 and 6, Blue No. 1 and 2, and Green No. 3) by the end of 2026 relies on working with industry; no federal rule has revoked them, and they're still authorized federally.

Yes, if it's true, but it's no substitute for allergen controls. Advisory statements are voluntary, and FDA says they must be truthful and not misleading and shouldn't be used as a substitute for good manufacturing practices. When FDA sampled dark chocolate labeled "dairy-free" in 2018–2019, it found potentially hazardous levels of milk in four of 52 products. In SQF, allergen management, including changeover cleaning and its validation, is Mandatory (2.8.1); in BRCGS, it's a fundamental requirement (5.3).

Federal law treats confectionery with a nonnutritive object partly or completely embedded in it as adulterated, unless an FDA regulation finds the object is of practical functional value and wouldn't make the product injurious or hazardous to health (21 U.S.C. 342(d)(1)). FDA's Import Alert 34-02, which names Kinder Surprise Eggs as an example, lets FDA detain such products from firms on its Red List without physical examination. Firm mini-cup gel and jelly candies that present a choking risk are covered by Import Alert 33-15.

Yes, if they contain mannitol or sorbitol and reasonably foreseeable consumption could reach 20 grams of mannitol or 50 grams of sorbitol a day. Those foods must carry the statement "Excess consumption may have a laxative effect" (21 CFR 180.25 and 184.1835). In SQF, label accuracy falls under 2.3.2.7; in BRCGS, under product labelling (5.2).

Because some Salmonella survive in low-moisture foods. FDA says some Salmonella can survive drying particularly well and are hard to kill with heat once they're dehydrated or in a low-moisture product such as chocolate. Raw cocoa beans, milk powder, nuts and coatings can carry it in, and a contaminated finished product isn't cooked by the consumer. Auditors look for a validated kill step such as roasting (SQF 2.5.1, Mandatory), supplier controls, and an environmental monitoring program (SQF 2.4.8; BRCGS 4.11.8).

Your initial certification audit takes place during the peak of your season, if you're a seasonal site. SQF treats a site as seasonal when its major production activities run no more than five consecutive months in a calendar year, and the initial certification audit then takes place during the peak operational part of the season. If a significant change in your season means your 60-day recertification window can't be met, you can agree with your certification body to temporarily reset the recertification date (Edition 9 Part A, 8.3 and 11.3). A plant that runs year-round with seasonal peaks isn't seasonal under this rule.

No. FDA's Food Traceability List under FSMA section 204 doesn't include candy, chocolate or cocoa. It does include nut butters, and Congress directed FDA not to enforce the traceability rule before July 20, 2028. Both SQF and BRCGS still require one-step-forward, one-step-back traceability (SQF 2.6.2; BRCGS 3.9).

Yes, but with relief for raw cocoa beans. FDA's FSVP rule names cocoa beans as an example of a raw agricultural commodity that can't be consumed without an appropriate control, and an importer of such a food may skip the usual supplier evaluation and verification if it documents that and meets the rule's other conditions (21 CFR 1.507(a)(1)). In SQF, imported materials still go through your Approved Supplier Program (2.3.4, Mandatory). See our FSVP guide.