BRC Traceability Requirements (Complete Guide for Issue 9)

During a BRCGS audit, auditors are assessing whether you can demonstrate effective control over product movement, ingredient usage, and recall readiness under real conditions. This means that traceability is typically tested in real-time during the audit.

The auditors objective is to verify that your site can:

• Identify where materials came from
• Show how they moved through production
• Confirm where finished products were sent
• Demonstrate all this quickly and accurately

Under Clause 3.9 specifically, auditors are looking for evidence that your traceability system is both well documented and operationally effective.

Please note we are not a regulator or legal body, and are only providing guidance and support towards compliance – we always recommend businesses refer to the BRC and relevant regulatory bodies for the most accurate and up-to-date guidance.

A common audit approach is for the auditor to select a finished product batch and request a complete backward trace. For example your auditor might choose a product from your dispatch records, a product label from the shop floor, or a sample from your warehouse stock. Your team then have to demonstrate:

• Which raw materials were used
• Which suppliers provided those materials
• The batch or lot numbers involved
• Packaging materials associated with the product
• Relevant production records

Essentially what you need to produce is a clear chain linking your supplier intake records, goods in documentation, production records and finished batch details to reconstruct the complete manufacturing history of your product.

The auditor might then reverse the process, and choose a raw material, packaging or rework batch for you to trace forward and identify:

• Which finished products contained that material
• Which production runs were affected
• Which customers received those products
• The quantities dispatched

This information is crucial in the case of a product recall, or quickly containing a food safety incident like contamination and allergen concerns.

Many auditors will also conduct a mass balance assessment as part of traceability verification, which involves checking whether the quality of the material received aligns with production usage, waste, rework and finished product output.

An example of this in practice would be that your site received 1000kg of a raw ingredient, 920Kg was used in production, while 50kg was recorded as waste, and you have 30kg in remaining stock.

If these quantities can’t be reconciled, auditors might question the accuracy of your records or the effectiveness of your site’s production controls. This is a common cause of traceability non-conformances.

While your business undertakes your BRC traceability exercises, auditors will also be examining:

Speed of traceability – under BRCGS guidance, traceability exercises are generally expected to be completed within approximately four hours. This means that you need to make sure your records are organised, data is accessible and that your system functions under pressure.

Data accuracy and integrity – auditors will examine whether your batch numbers match across records, quantities reconcile correctly, dates align logically, and whether material movements are fully documented.

Staff understanding – to determine if traceability knowledge exists beyond the quality assurance team, auditors might ask production or warehouse staff questions on batch identification, label management etc.

Traceability procedures and documentation – the auditor will review your documented procedures to confirm that your traceability system is formally defined. They’ll usually look at things like batch coding rules, rework procedures, recall procedures and previous traceability test records.

Traceability non-conformances are some of the most common issues identified during BRCGS audits. In many cases though, businesses believe their traceability systems are functioning effectively. However, when put under pressure in audit conditions problems often emerge such as the following…

• Incomplete link information between raw materials, work-in-progress and finished products
• Inconsistent rework usage records on things like containers, additions or combined batches
• Traceability exercises taking longer than the four hour expectation
• Inaccurate or incomplete data such as batch numbers, production records, intake dates etc.
• Mass balance discrepancies meaning figures can’t be reconciled
• Traceability gaps for packaging materials
• Overreliance on individual staff knowledge with long-serving employees and informal processes
• Lack of routine traceability testing resulting in outdated procedures and system gaps

While BRCGS does not require businesses to use digital traceability systems, many manufacturers are finding that manual systems are becoming increasingly difficult to manage as operations grow.

Sure, paper records and spreadsheets can often meet traceability requirements in principle, but challenges typically arise when you need to retrieve information quickly during audits, product recalls, customer investigations etc. Issues like missing records, inconsistent batch coding or lengthy data reconciliation can all increase the risk of BRC non-conformances.

Digital traceability systems can help you address these challenges by centralising your traceability records and providing a clearer view of material movement throughout your premises. In the context of this article, digital traceability can support your BRC compliance strategies by:

Having a digital system in place with centralised traceability information eliminates the need for your team to manually sift through piles of paperwork, and instead provides instant access to supplier, production, stock and dispatch records.

The Stevens Traceability System, for example, comes packaged with a dedicated reporting suite and library of dozens of reports ready to be produced at the click of a button to allow you to focus on compliance and demonstration, rather than information gathering.

Having a well designed traceability system in place will provide your team with visibility across your entire production line, from goods-in through to dispatch, providing vital insights into your operations and simplifying routine traceability exercises and real-world incident investigations.

Our own system has been developed specifically to help food manufacturers achieve this level of control. By linking ingredients, packaging, production batches, stock movements and sales orders within a single platform, the Stevens Traceability System provides a clear and auditable traceability chain throughout your business.

In the event of a product withdrawal or recall, you need to be able to rely on the speed and accuracy of your system for a prompt, effective response.

Electronic traceability allows your team to perform forward and backward traceability, meaning you’ll be able to rapidly identify any affected batches and prepare a more controlled response to any food safety incidents.