A Breakdown of the Updates to AB310, F926, SD404, and the New P708
BRCGS has released a new round of amendments across several Position Statements, updating requirements for Agents & Brokers (AB310), Food Safety (F926), and Storage & Distribution (SD404), while also introducing a brand-new Position Statement for Global Standard Packaging Materials, Issue 7 (P708). These changes align the standards with the GFSI Benchmarking Requirements (BMR) 2024 and go into effect August 10, 2026.
If your site is certificated to any of these standards, now is the time to review the updates and prepare, because certification bodies will begin assessing against them from that date forward.
Agents & Brokers
Four clauses received meaningful clarification in this update:
- Clause 2.7.1 now makes clear that prerequisite programmes must be in place before hazard and risk analysis is conducted, and that existing controls within those programmes should be documented and factored into the plan. In short, risk analysis can no longer stand apart from the foundational controls already operating in the business.
- Clause 3.6.1 sharpens what counts as “key data” in product specifications, explicitly calling out chemical, microbiological, physical, and allergen parameters, and requiring that such data be grounded in legislation or sound science.
- Clause 4.3.1 adds an explicit competence requirement for personnel conducting product defence assessments, ensuring reviewers understand the associated risks rather than treating the exercise as a checkbox activity.
- Clause 4.8.2 introduces a similar competence expectation for vulnerability (food fraud) assessments, encouraging a multi-disciplinary approach that draws on technical, purchasing, and supply chain expertise.
Across all four, the theme is consistent: BRCGS wants risk-based decisions backed by demonstrable competence, not paperwork alone.
Food Safety
The Food Safety standard sees one notable change in this release:
- Clause 7.4.2 now explicitly requires protective clothing to include snoods for facial hair and suitable protective footwear where necessary. The update reinforces that personal protective equipment isn’t limited to garments; footwear and hair coverings are equally part of contamination control, particularly in higher-risk areas of the facility.
Storage & Distribution
SD404 receives the broadest set of updates in this release, touching supplier management, subcontractor agreements, competence, equipment, and scope:
- Clause 3.5.1.2 strengthens supplier specification requirements to include chemical, microbiological, physical, and allergen parameters, keeping expectations consistent with the changes made to AB310.
- Clause 3.5.2.1 reinforces subcontractor agreements, requiring that product-handling conditions and safety parameters be clearly defined contractually, so outsourced activities are controlled to the same standard as in-house operations.
- Clause 3.5.3.1 and Clause 4.2.1 both introduce explicit competence requirements, for vulnerability assessments and product security/food defence, respectively, mirroring the AB310 changes.
- Clause 6.1 clarifies that equipment must not only suit its purpose but also be stored to minimize contamination risk, including control over equipment movement between areas.
- Clause 6.4.5 adds detail to cleaning equipment controls, requiring hygienic design, clear identification, and proper storage.
- Section 17 expands the scope of contract processing operations to include irradiation, alongside the existing coverage of chilling, freezing, tempering, defrosting, and high-pressure processing. Any site performing contract irradiation now has a formal obligation to operate in accordance with product owner specifications.
- Clause 17.3 broadens process monitoring beyond temperature alone, now referencing real-time temperature, pressure, and irradiation as parameters to be monitored and, where appropriate, tied to an automatic failure alarm system.
Sites performing contract processing, in particular, should take a close look at Section 17 and Clause 17.3, since irradiation is now formally within scope.
New: Global Standard Packaging Materials, Issue 7
Alongside the amendments above, BRCGS has issued a brand-new Position Statement for the Global Standard Packaging Materials, Issue 7:
- Clause 4.4.1 now explicitly requires that personnel involved in threat assessments and product defence plans be appropriately trained, in line with Clause 6.1. BRCGS notes this formalizes an expectation that was already implicit in the standard.
- Clause 4.8.2 introduces two new requirements: disinfection procedures must be implemented and maintained alongside cleaning where appropriate, and cleaning procedures must be validated and verified based on the risk associated with the product’s intended use.
- Appendix 8 adds a formal glossary definition for disinfection, closing a gap that previously left the term undefined.
Why This Matters
A common thread runs through nearly every one of these changes: competence. Whether it’s vulnerability assessments, product defence, or food defence training, BRCGS is pushing certificated sites to demonstrate that the people conducting risk-based activities actually understand the risks, not just that a form was completed. Combined with sharper expectations around specifications, subcontractor agreements, and equipment storage, these updates are a reminder that GFSI benchmarking continues to push toward systems that are verifiable and genuinely risk-based.
Why Work with PJRFSI?
At Perry Johnson Registrars Food Safety, Inc. (PJRFSI), we help certificated sites stay ahead of standard changes like these instead of scrambling to catch up. Our approach includes:
- Auditors who understand the practical implications of each Position Statement update, not just the letter of the clause
- Clear, actionable guidance on what documentation and competence records auditors will expect
- Industry expertise across BRCGS Agents & Brokers, Food Safety, Storage & Distribution, and Packaging Materials, along with other GFSI-recognized schemes
Final Thoughts
With an effective date of August 10, 2026, certificated sites have a limited window to review these Position Statement changes, update procedures, and ensure personnel involved in risk and vulnerability assessments can demonstrate the competence BRCGS now expects in writing. Waiting until your next audit to find the gaps is the hardest way to close them.
If you have questions about how these updates affect your certification, contact PJRFSI to talk with our team.
