What BRCGS clause 3.5 asks for
Section 3.5 of the BRCGS Global Standard for Food Safety covers the management of suppliers of raw materials and packaging, suppliers of services and outsourced processing. In short, you must be able to show that:
- every raw material and packaging item has been risk-assessed;
- each supplier has been approved using a method proportionate to that risk;
- you keep an up-to-date list of approved suppliers;
- goods are checked on acceptance in line with the risk; and
- supplier performance is monitored and acted on.
This guide summarises good practice. Always check wording against the current issue of the Standard and its interpretation guidance, as clause numbering and detail change between issues.
Step 1: Raw material risk assessment
The raw material risk assessment is the foundation. Everything else — approval method, testing, acceptance checks — should be justified by it. For each raw material (or group of similar materials), assess the likelihood and severity of:
- Allergen contamination — both declared allergens and cross-contact at the supplier.
- Foreign bodies — stones, glass, metal, plastic, wood, pests.
- Microbiological contamination — especially for ready-to-eat or no-further-kill ingredients.
- Chemical contamination — pesticides, mycotoxins, heavy metals, cleaning chemicals.
- Variety or species cross-contamination — relevant where claims depend on it.
- Substitution and fraud — link to your vulnerability assessment (VACCP).
- Legislative controls — any hazards linked to materials under specific legal limits.
Score each hazard, record the controls in place, and assign an overall risk rating (for example low, medium, high). Review the assessment at least annually and whenever a new material, new supplier, new origin or new intelligence (such as a recall or a price spike suggesting fraud risk) arises.
Step 2: Choosing a supplier approval method
BRCGS expects the approval method to reflect the risk. The common options are:
| Method | Suitable for | What to keep on file |
|---|---|---|
| Valid certification to BRCGS or another GFSI-benchmarked standard | Most suppliers, including high-risk ones | Current certificate, confirmation that the audit scope covers the materials you buy, expiry date tracked |
| Supplier audit by a competent food safety auditor | Uncertified suppliers, or high-risk suppliers where extra assurance is needed | Audit report covering product safety, traceability, HACCP and good manufacturing practice; close-out of findings |
| Supplier questionnaire | Low-risk suppliers only, where justified by the risk assessment | Completed, signed questionnaire reviewed by a competent person |
Whichever method you use, record who approved the supplier, when, on what basis, and which materials the approval covers. Approval is for a supplier and its materials — a certified site is not automatically approved for products outside its audit scope.
Agents, brokers and exceptions
Where you buy through an agent or broker, you still need to know the identity of the last manufacturer or packer of the product (or the consolidation place for bulk commodities), and to approve on that basis — either directly or through the agent's own approval programme, provided you have seen evidence of it.
Occasionally a customer will specify a supplier you would not otherwise approve. The Standard allows for exceptions like this, but you must document them and still apply suitable controls such as product testing on receipt.
Step 3: Acceptance checks and ongoing monitoring
Acceptance at goods in
Define what happens on delivery for each material, based on risk: visual inspection, temperature checks, certificate of analysis (CoA) review, sampling or laboratory testing. Make sure goods-in staff know the specification limits and what to do when a delivery fails.
Performance monitoring
Review each supplier at a set frequency against measurable criteria, for example:
- number of rejected deliveries and non-conformities;
- complaints traced back to the supplier's material;
- certificate and specification status (current or expired);
- responsiveness to corrective action requests; and
- on-time delivery and documentation accuracy.
Poor performance should trigger action: a corrective action request, increased testing, a supplier audit, or removal from the approved list. Non-conformities raised against suppliers belong in the same system as your internal ones — see our guide on non-conformance and CAPA management.
Records auditors expect to see
- A raw material risk assessment, with review dates, covering every material in use.
- A documented supplier approval and monitoring procedure.
- The approved supplier list, showing approval basis and status.
- Current certificates, audit reports or questionnaires for each supplier.
- Current raw material and packaging specifications.
- Goods-in records, CoAs and test results.
- Supplier performance reviews and resulting actions.
Keeping these linked is where most sites struggle: a certificate expires, nobody notices, and the approved supplier list is suddenly wrong. SoftSpec's BRC compliance software tracks supplier certificates and expiry dates, collects specifications and questionnaires through a supplier portal, and keeps the approval history with a full audit trail.
Frequently asked questions
What does BRCGS require for supplier approval?
A documented raw material risk assessment, a risk-based supplier approval and monitoring procedure, an up-to-date approved supplier list and ongoing performance review. Approval is typically based on GFSI-benchmarked certification, a supplier audit, or — for low-risk suppliers only — a questionnaire.
What hazards should a raw material risk assessment cover?
Allergens, foreign bodies, microbiological and chemical contamination, variety or species cross-contamination, substitution or fraud, and hazards linked to legally controlled materials.
How often should supplier approval be reviewed?
Track certificates to expiry, review supplier performance at a risk-based frequency, and review the raw material risk assessment at least annually or when anything changes.