BRCGS Traceability and Recall: How to Be Ready When It Counts

How BRCGS handles traceability, product withdrawal, and recall readiness. What South African manufacturers need in place — and how to test it before the auditor does.

Traceability is not a filing system. It is an emergency response capability. When something goes wrong — a contaminated ingredient, a mislabelled allergen, a supplier failure — your traceability system is what stands between a controlled withdrawal and a public health crisis.

BRCGS Food Safety Issue 9 treats traceability accordingly: not as a documentary requirement to satisfy once a year, but as a live, tested system that must work under pressure, on any day, in any shift. South African manufacturers pursuing or maintaining BRCGS certification need to understand exactly what that means — and whether their current setup would survive a real event.

1. What BRCGS Requires for Traceability

The foundational requirement is in clause 3.9.1: every site must have a documented traceability procedure that describes how the system works and what labelling and records it depends on. That procedure must be understood by the people who will use it — not filed in a folder only the QA manager has access to.

The scope of traceability extends one step back and one step forward from the site: back to the direct supplier of each raw material, and forward to the customer who received finished product. BRCGS does not require you to trace raw materials all the way to the farm unless the farm is your direct supplier. But within that chain, traceability must be complete.

Clause 3.9.2 adds that identification must be adequate at every stage: raw materials, primary packaging, intermediate and semi-processed products, part-used materials, finished product, and materials held pending investigation. Nothing moves through your facility without a traceable identity.

There is no prescribed tool or format. Paper-based systems are acceptable if they work. Digital systems are acceptable if they are secure and backed up. What BRCGS requires is that the system functions — and that you can prove it.

2. Raw Material to Finished Product — the Traceability Chain

Traceability must run in both directions through your entire production process.

Working backwards: a batch of finished product must be linkable to the specific raw material batches used to make it, the supplier who provided those materials, the date they were received, and the approval status of that supplier at the time.

Working forwards: a raw material batch code must be linkable to every finished product batch that used it, the customers those batches were dispatched to, and the dispatch dates.

In practice, this means your system must connect:

• Supplier delivery notes and goods-received records (with supplier batch codes)
• Intake identification and internal batch or lot codes
• Production records (which raw material batches were used in which product runs)
• Rework records (clause 3.9.4 — traceability must be maintained through rework operations)
• Finished product labelling (batch codes that can be read back into production records)
• Dispatch records and customer delivery documentation

Where product is broken into smaller consignments for individual customers, your system must be able to identify every one of those customers and confirm what information they received on packaging. If a customer needs to act on a recall, they need enough information to do so. Traceability is only useful if it reaches the people who need it.

Specific claims — organic status, farm assurance logos, allergen-free designations — require full traceability and validation. The chain of custody must support the claim on the label.

3. Product Withdrawal vs Product Recall — the Distinction Matters

These two terms are used loosely in industry, but BRCGS defines them precisely, and the distinction determines who you contact, how fast, and what actions you must take.

Product withdrawal (clause 3.11.2 glossary): the return of out-of-specification or unfit products from customers, but not from final consumers. A withdrawal is typically used when the product has not yet reached the point of sale to the public, or when the concern is a quality issue rather than a safety risk to consumers.

Product recall: any activity aimed at achieving the removal of an unfit product from customers and final consumers. A recall is triggered when unsafe or potentially unsafe product has entered the consumer market and poses a risk to people.

The decision between withdrawal and recall should not be made on the fly under stress. Your documented procedure (clause 3.11.2) must include guidelines for deciding which action is required so that the recall management team is not making a judgment call without a framework.

The consequences of getting this wrong are significant:

• A withdrawal treated as a recall when it isn't one creates unnecessary market disruption and brand damage.
• A recall treated as a withdrawal when product is already with consumers is a serious regulatory and ethical failure.

Your procedure needs decision criteria. Write them down. Test them.

4. Mock Traceability Exercises — How to Run One, What Auditors Want to See

Clause 3.9.2 requires annual testing of the traceability system. Clause 3.11.3 requires annual testing of the full incident management procedure, including the withdrawal and recall process. These are related but not interchangeable — a traceability test alone does not satisfy the recall procedure test.

Running a traceability exercise:

1. Select a specific raw material batch code or a finished product batch — auditors will often choose this for you during the vertical audit, so your team needs to be able to run the exercise with any product, not just one they have prepared for.
2. Trace it in both directions: backwards to the supplier and forwards to the customer.
3. Complete a mass balance / quantity reconciliation — account for the quantity received, the quantity used in production (by recipe and batch), the quantity of finished product dispatched, any rework incorporating the material, and any remaining stock.
4. Record the time started and the time completed.
5. Document what you found, any gaps encountered, and any corrective actions needed.

Running a recall procedure test (clause 3.11.3):

This goes beyond traceability. The test must include:

• Activation of the recall management team (confirm all contact details work, including out-of-hours numbers)
• Decision-making: is this a withdrawal or recall? Who makes the call?
• Communication plan: who contacts the customer, the certification body, the regulator, and in what order?
• Logistics: how is affected product isolated, quarantined, and accounted for?
• Record-keeping: are timings being logged throughout?

The BRCGS auditor wants to see that the procedure works as a system, not that someone can find batch records. Records of the test must be retained, including a review of results and any improvements implemented.

5. Time Limits — the 4-Hour Challenge and Why Speed Matters

Clause 3.9.3 sets an expectation that full traceability should be achievable within 4 hours. When information is required from external parties — such as supplier batch details — 1 working day is the outer limit.

This is not an administrative target. It reflects the operational reality of a food safety incident. Regulatory authorities, retailers, and the public do not wait. Every hour a contaminated product remains unaccounted for in the supply chain is an hour of compounding risk.

The mass balance exercise is not expected to be completed within 4 hours in all cases — it can be resource-intensive. But the 4-hour window applies to traceability itself: knowing where the product went and where the materials came from.

If your last traceability exercise took longer than 4 hours, the standard guidance is clear: review where the retrieval of information was slow and identify improvements. Common bottlenecks include:

• Production records stored in formats that are difficult to search (handwritten logs with inconsistent batch code formats)
• Dispatch records held by a logistics team that uses a different coding system
• Raw material supplier batch codes not carried forward into internal records
• Key records accessible only to one person who is not always available

Time your exercises. Keep the records. Know your weak points before the auditor finds them.

6. Record-Keeping Requirements

Traceability is only as good as the records that support it. Under BRCGS Issue 9, records must be:

• Legible and accurate at the point of creation
• Retained for an appropriate period (at minimum, the shelf life of the product plus a defined buffer — typically 12 months beyond best-before date, or as required by law)
• Accessible in a timely manner — not archived offsite or in a system that requires specialist access

The core records your traceability system depends on:

During the vertical audit, the BRCGS auditor will work through this chain with a specific batch. They will check supplier approval records, goods receipt, process monitoring records (temperatures, metal detector checks), and dispatch documentation. Every link in the chain must be present and consistent.

7. When Things Go Wrong — Incident Management and Root Cause

An actual product recall or withdrawal is not a failure of your food safety system — it is your food safety system working. The real failure is either not detecting the problem, not acting on it fast enough, or failing to prevent recurrence.

Clause 3.11.1 requires a documented incident management procedure covering a range of scenarios: contamination events, service disruptions, cyber-security failures, malicious contamination, fire, and flood. The procedure must be capable of being operated at any time — not just during business hours.

Clause 3.11.4 is specific: in the event of a significant food safety, authenticity or legality incident — including a product recall, regulatory enforcement notice, or food safety-related withdrawal — you must notify your certification body within 3 working days. Within 21 calendar days, you must provide corrective action, root cause analysis, and a preventive action plan.

Root cause analysis is not optional following a recall or significant incident. It must be conducted systematically (5-Whys, fishbone, or equivalent), documented, and linked to preventive actions with defined owners and target dates. The certification body needs to see that the root cause has been identified and that recurrence has been addressed — not just that the immediate problem was resolved.

Key timings to record during any incident or test:

• When the incident or test was initiated
• Times of internal communications and key decisions
• When traceability and mass balance exercises were started and completed
• When customers, regulatory authorities, and the certification body were contacted

These records are evidence of a functioning system. They also protect you legally and commercially if a dispute arises about the adequacy of your response.

8. Practical Checklist: Is Your Traceability System Audit-Ready?

Use this before your BRCGS audit — or before the problem that makes you wish you had.

Documentation

• Traceability procedure is documented, current, and accessible to relevant staff
• Withdrawal and recall procedure is documented and covers all required elements (clause 3.11.2)
• Recall management team roles and responsibilities are defined and up to date
• Out-of-hours contact details for team members, customers, suppliers, certification body, and regulator are verified

Identification and Records

• All incoming raw materials receive a unique internal batch code linked to the supplier batch code
• Production records link raw material batch codes to finished product batch codes
• Rework is tracked and included in production records
• Finished product labels carry batch codes that can be read back into production records
• Dispatch records capture customer identity, product batch codes, quantities, and dates

Testing

• Full traceability exercise completed within the past 12 months — both directions
• Mass balance completed as part of the exercise
• Exercise was timed and the timing recorded
• Full recall procedure test completed within the past 12 months (not just a traceability exercise)
• Test records include a review of results and any corrective actions taken

System Integrity

• Traceability can be demonstrated within 4 hours for an internally-held product
• No single point of failure in records access (records are not dependent on one person or one system without backup)
• Decision criteria for withdrawal vs recall are documented in the procedure
• Staff who would be involved in a real withdrawal or recall know their roles

If any of these boxes cannot be checked, that is your action list before the next audit.

What Auditors Are Actually Looking For

During the BRCGS audit, the vertical audit will test your traceability system with a real product or ingredient. The auditor is not testing whether you have a procedure — they are testing whether the procedure works in practice, in real time, with the records your team actually maintains.

The most common findings in traceability-related non-conformances in South African manufacturing sites include: batch codes that are present on labels but not consistently recorded in dispatch documents; supplier batch codes received on delivery notes but not captured into internal records; production records that record batch code ranges rather than specific lot codes; and recall procedures that list contacts who have since left the business.

None of these are complex problems. All of them are correctable before the audit. None of them are acceptable on the day.

A well-designed traceability system is not a compliance burden. It is a business continuity tool. The ability to identify and contain a problem within hours — rather than days — is what separates a manageable incident from a reputational crisis.

*Want to understand how traceability performs under real audit pressure? See our gallery: Traceability Under Pressure — a case-by-case look at how BRCGS traceability requirements play out in South African food manufacturing contexts.*