When the biggest customer of Kameeldoring Trading asked for BRCGS Agents and Brokers certification before the next supply contract, the owner treated it as a paperwork job. Kameeldoring imports rice, dried beans and canned tomatoes through Durban, stores them in two contracted East Rand warehouses and sells to manufacturers and a wholesale group from a small Midrand office. The quality coordinator bought a template manual and booked a pre-assessment, and it went wrong in the first hour, because the auditor barely opened the manual. She asked who had signed the policy and whether he still worked there, what the culture plan had changed, when leadership had last reviewed supplier performance, why a tomato packer was approved on a questionnaire, and what would stop a cheaper bean variety being passed off as the one specified. Every answer belonged to the owner. BRCGS Agents and Brokers certification is awarded to the company, but much of what the auditor tests was decided by the people who sign the contracts and set the budgets.
In short
- The Global Standard for Agents and Brokers, Issue 3, covers companies that buy, sell or arrange trade in food, packaging, pet food or consumer products without making or processing them. Issue 3 audits have run since 1 April 2022.
- Part I picks out three key components, starting with senior management commitment, and the Standard expects that commitment to show up in hard evidence.
- Leaders sign the policy, own a product safety and quality culture plan, receive progress on objectives at least every six months and hold a management review at least once a year (1.1.1 to 1.1.4).
- Manufacturers and packers you never visit are approved by one of four routes, with questionnaires only for low-risk products (4.1.2). Service providers are approved, put under contract and reviewed at least once a year (4.2.4).
- A vulnerability assessment covering every product group is formally reviewed each year, with a mitigation plan for products at particular risk (4.8).
- Unlike the Food Safety Standard, Issue 3 has no fundamental clauses. Every section with a shaded statement of intent has to be met.
Why customers ask for BRCGS Agents and Brokers certification
A trader sits in the middle of the chain of custody. Your customer buys from you, but the food was made by a packer you chose, moved by a haulier you booked and stored by a warehouse you contracted. The customer cannot audit all of them, so it wants evidence that you have. Importers often carry legal duties for what they land too, and may be asked for the paperwork by an authority or a customer long after the goods are sold. A certificate is the shorthand for all of that.
Part I lists what certification gives a business: an accredited third-party audit, a listing on the public BRCGS Directory where customers check your status and scope, support for their own due diligence and, sometimes, a certificate they accept instead of auditing you themselves. Retailers, food service groups and manufacturers in many countries look for a BRCGS certificate when they vet a supplier, and Issue 3 was written with the Global Food Safety Initiative (GFSI) benchmark in mind. Usually the request arrives as it did at Kameeldoring: a major customer asks, often because its own customers expect it, and there is a contract date attached.
First, check it is the right Standard for what you do.
| Your business | Does Agents and Brokers fit? | Why |
|---|---|---|
| A broker: you take title to goods and sell them on to businesses, never to the public | Yes | One of the two types of company the Standard was written for. Selling straight to consumers is not part of the role. |
| An agent or non-manufacturing service provider: you arrange trade between a manufacturer and its customer and never own the goods | Yes | The second type: your services make the trade safe and legal without the title passing to you. |
| An office that only performs services such as product inspection or import processing | Possibly | It can be in scope if no other BRCGS Standard covers the activity. |
| A company that also runs its own warehouse or cold store | For the trading activity only | Running a store is a job for the BRCGS Storage and Distribution Standard, not this one. |
| A trader in livestock, livestock feed, bulk fuels or pharmaceuticals | No | These product categories are excluded. Food, packaging, pet food for domestic animals and consumer products are eligible. |
The Standard covers product safety, authenticity, quality and legality only, and it certificates an office: a dedicated workplace with at least two people, file access and a registered postal address. If your team needs the structure first, the Introduction to BRCGS for Agents and Brokers Issue 3 course walks through it section by section.
What senior management has to show the auditor
Section 1 is about you rather than the quality coordinator. Its statement of intent is shaded, so every certificated company must meet it, and the auditor tests it by reading what leadership has signed and minuted, checking that budgets and people match what was promised, and asking staff questions only a working system lets them answer. A buyer who cannot say what the policy commits the business to tells the auditor more than a framed copy on the wall.
| What you must be able to show | Clause | What the auditor looks for |
|---|---|---|
| A policy committing the business to safe, legal, authentic products of the specified quality | 1.1.1 | Signed by whoever is in overall charge of the company today, shared with every member of staff, and explainable by them in their own words. |
| Objectives for safety, authenticity, legality and quality | 1.1.3 | Each objective has a target, the people responsible know it, and progress comes back to leadership at least twice a year. |
| An escalation route | 1.1.5 | Significant issues reach senior management fast enough for urgent ones to be resolved. |
| Keeping up to date | 1.1.7 to 1.1.9 | Horizon scanning for emerging risks and the law in each destination market; registrations wherever the law requires them (confirm which with a regulatory specialist); your own genuine copy of the current Standard, with position statements tracked. |
| A clear structure with named deputies | 1.2.1, 1.2.2 | An organisation chart, responsibilities that managers understand, documented deputies, and staff who know their part and can reach the procedures they work to. |
The culture plan, management review and resources each have a section below. Section 1 also holds the duties that arise around the audit itself: booking recertification on time, attending the opening and closing meetings, and making sure last year’s root causes were really fixed. The BRCGS Agents and Brokers Issue 3 for Management course covers both sets of duties with case studies from fictional South African trading businesses.
The product safety and quality culture plan, for an office rather than a factory
The culture plan in clause 1.1.2 is new in Issue 3, and owners often try to delegate it. The Standard does not let you. Senior management defines the plan and keeps it alive, and it has to reach every part of the business whose decisions affect safety and quality. In a trading company that means buying, logistics and sales at least as much as the technical function, because the decisions that create risk are made there: which supplier is accepted during a shortage, whether a delivery with a broken seal is questioned, whether a customer’s new labelling requirement is passed on.
It must cover at least four strands, set out what will happen, when and how success will be judged, and later look back at whether finished activities made a difference. An eight-person office can run a perfectly good plan if every activity is real and the results go back to the people who took part.
| Strand | What it can look like in a trading business | How you might measure it |
|---|---|---|
| Communication, inside the company and along the supply chain | A short monthly briefing on supplier issues, complaints and near misses; a yearly letter to manufacturers and service providers setting out what you expect and why | Attendance; acknowledgements received from suppliers and providers |
| Training | Buyers trained on the approval routes before they approve anyone; logistics staff shown what to check when a load or seal looks wrong | Competency checks after training; share of buyers trained before their first approval |
| Employee feedback | An anonymous survey twice a year, and a simple way for anyone to raise a concern, with answers reported back | Response rate; number of issues raised and closed; what changed as a result |
| Measuring how well safety and quality work is done | Objectives such as supplier approvals completed on time, complaints per thousand cases and traceability test times | The six-monthly objectives report and the trend since the last one |
Two failures recur: the poster campaign, with slogans but no activity or measure behind them, and the plan that is never reviewed, so the same activities roll forward whether they worked or not. Unlike the Food Safety Standard, Issue 3 does not oblige you to set up a confidential way for staff to raise concerns, but a simple speak-up channel is still a sensible way to feed the employee-feedback strand.
Management review, objectives and escalation: proving the system works
The management review in clause 1.1.4 is where an auditor checks whether leadership is steering the system or just signing it. It happens at planned intervals and at least once a year, senior management attends, and the agenda is not yours to choose. As a minimum it has to consider:
- how your suppliers performed over the period;
- what customers told you: complaints, and how they rated you in their own reviews;
- what went wrong: incidents and the corrective actions they triggered, results outside specification and materials that did not conform;
- what auditors found, whether internal, customer or certification body;
- whether your hazard and risk analysis, product security and anti-fraud controls are working;
- the resources the business needs next;
- whether last review’s actions were actually completed.
The minutes then have to show decisions: objectives revised, actions with owners and dates, and those actions communicated and completed in time. A review that lists the inputs and concludes all is well, year after year, reads as a meeting nobody prepared for. Remember too that the Standard’s glossary treats annual as within twelve months of the last time, so a review held in March and then in May of the following year is late.
Between reviews, objectives are reported at least every six months (1.1.3), and the escalation route in clause 1.1.5 decides how fast bad news travels. If a buyer learns on a Thursday that a packer’s certificate has been suspended, does the managing director hear that day, and is it written down? Named deputies (1.2.1) keep that working when the usual person is on a plane.
Resources: the budget lines behind the certificate
Clause 1.1.6 makes leadership responsible for giving the business enough people, money and time to keep its products safe, genuine, legal and to specification. Auditors rarely raise resources as a finding on its own; they notice the same gap in three places and follow it back to a budget or headcount decision. In trading businesses, too few people or too little budget sits behind many findings.
- A competent lead for the hazard and risk assessment (2.1). Without one you have a consultant’s plan nobody can explain. Outside help is allowed; ownership stays with you.
- A risk-based testing programme (4.4.1). Without it, risks flagged in the supplier risk assessment never reach a sampling plan. The Standard’s own example of a major non-conformity is this gap.
- Checked laboratories (4.4.2, 4.4.4). Certificates of analysis from a laboratory nobody has verified prove very little.
- Supplier audits, or time to verify certificates (4.1.2, 4.1.6). Otherwise the file holds a certificate for the wrong site, the wrong scope or a lapsed date.
- Independent internal auditors and training before people start (3.5.2, 5.1.1). Otherwise people audit their own work, and temporary or home-based staff work without a training record.
Most of these costs are smaller than the finding, the extra testing and the customer conversation that follow when they are missing, and the management review is where the Standard expects them to be raised and decided.
Approving manufacturers and packers you never visit
This is where a trading business carries most of its exposure, and where commercial pressure pushes hardest. Section 4.1 expects a risk-based procedure for approving and monitoring the last manufacturer or packer of every product you trade, not only the company on your purchase order. The risk assessment behind it weighs where each product comes from and how open it is to adulteration or fraud, alongside its nature and risks, what your customers require, the law where it will be imported or sold, and whether it carries the customer’s own brand. Revisit it at least every three years even when nothing has changed, and sooner if you change a product, process or supplier, spot a new risk, or have a specific product recalled or withdrawn.
The risk assessment then decides which approval route you are allowed to use.
| Approval route | When it is acceptable | What has to be on file |
|---|---|---|
| Certification | The manufacturing or packing site holds a valid BRCGS or other GFSI-benchmarked certificate, and its scope covers the product you actually trade | The certificate, checked for site, scope and expiry on the BRCGS Directory or the scheme’s own database |
| Supplier audit | Any product, including high-risk ones | An audit by an experienced auditor with proven product safety competence that looked at the HACCP or hazard and risk review, a traceability test, the food defence and authenticity plans, good manufacturing practice and product safety generally. If someone else did it, proof of that auditor’s competence and the full report, not a summary |
| Questionnaire | Food or non-food lines your risk assessment rates as low risk, with the reasoning written down | The returned questionnaire, showing the supplier has working action plans for product safety, food defence and authenticity, checked and signed off by someone competent to judge it |
| Contract, specification or trading history | Low-risk non-food lines only, again with the reasoning written down | A contract or specification that is binding in law, or a track record backed by documented performance reviews with satisfactory results |
Three situations need a management decision rather than a buyer’s judgement. Buying through another agent or broker, you must still know who made the product, or for bulk commodities where it was consolidated (4.1.4), and have enough information to approve that site unless the intermediary is certificated to this Standard or another GFSI-benchmarked one (4.1.5). When a customer names the supplier and carries the liability, approval may not apply, but you keep a record of the customer’s requirement. And when a customer asks you to disclose the last manufacturer so that it can approve the site, clause 3.4.3 expects you to provide it, however much you would prefer to protect your supplier base.
Approval is not a one-off. Clause 4.1.7 expects a documented, risk-based review of each manufacturer or packer against defined criteria such as complaints, test results, regulatory alerts and customer rejections. A questionnaire approval needs a fresh questionnaire at least every three years, and your supplier contracts must oblige suppliers to warn you of significant changes in between, including any change to their certification. Where a supplier was approved on a questionnaire, a contract or trading history, you also verify its traceability at approval and at least every three years (3.7.4). Our internal and supplier auditing practices course covers the skills behind this, and our guide to horizon scanning and supplier certificate checks shows how to verify a certificate in minutes.
Service providers: the cold store, the haulier, the relabeller and the laboratory
Section 4.2 has a bordered statement of intent, so it may not apply to every company, but it falls away only if you use no service providers at all. If someone else stores, moves, tests, relabels or disposes of your product while it is your responsibility, the Standard expects you to have approved them, evaluated the risks they bring and put effective controls in place.
Approval is risk-based: weigh what the provider could do to product safety and quality, whether its work keeps you legal (on weights and labels, for example), what your customers expect, and the security risks your own threat and vulnerability assessments have found. The basis can be a BRCGS, GFSI-benchmarked or ISO certificate, an audit as broad as a supplier audit, a recorded track record, a questionnaire checked by someone competent, or, for a waste contractor for example, its operating licence. Each provider then gets a formal performance review as often as its risk demands, and never less than once a year (4.2.4).
The contract is where most of the control lives. These are the terms worth checking in every agreement with a cold store, warehouse, haulier or relabeller:
- Service requirements and safety risks: temperature, hygiene, pest control and handling expectations written in, not assumed (4.2.3).
- Incidents: a clear route for the provider to report an incident or suspected non-conforming product promptly, day or night (3.10.1, 3.11.1).
- Records on request: copies of intake checks, temperature logs and dispatch records, typically within one working day (3.3.3).
- Changes to their own HACCP plan: if you rely on a provider’s plan to control a hazard, the contract requires notice of significant changes before they are made, and a competent person on your side reviews them (2.8.1).
- Further subcontracting: what the provider may and may not pass on to another company, and on what terms (4.2.5).
- Security: the measures from your threat assessment of subcontracted transport and storage, such as sealed vehicles, seal number checks and restricted access (4.3.1).
- Holding product: secure storage arrangements so implicated stock cannot be released by mistake while you decide what happens to it (3.10.1).
A certificated provider can save work as well as risk. If it holds a BRCGS or GFSI-benchmarked certificate that includes food defence, you need not verify its security yourself (4.3.2), and if its HACCP plan sits within an accredited certification scope you can rely on it without your own competent review of the plan, though the contract must still require notice of significant changes (2.8.1).
Product authenticity: the fraud question owners have to answer
Traders meet food fraud in ways a manufacturer often does not. Products change hands several times, arrive from many origins and are often bought on price, and the person accepting an unusually good offer is rarely the person who would manage the recall. Issue 3 strengthened the authenticity requirements.
- Threat information (4.8.1). Access to information on historical and emerging threats in your supply chains, from trade associations, government or specialist sources, which someone actually reads.
- Vulnerability assessment (4.8.2). Every product or product group is scored for how likely it is to be diluted, substituted or adulterated: what kind of product it is, whether it has been faked before, how much a fraudster stands to gain, how easily someone could get at it in the chain, and whether your routine tests would spot a problem. Market shifts should prompt an update, and there is a formal review every year.
- Mitigation plans (4.8.3). Where a product scores as especially vulnerable, a written plan sets out the checks or tests that bring the risk down.
- Claims (4.4.3). If you sell on origin, certified-scheme or identity-preserved status, the supplier backs it with evidence or someone independent checks it.
- Supplier approval and internal audit (4.1.1, 3.5.1). Fraud potential is part of every supplier risk assessment, and the fraud mitigation plan is within the scope of your internal audits.
A price well below the market, a new origin during a shortage or an intermediary who will not name the packer are risk signals, and buyers need permission from the top to treat them that way. Our step-by-step guide on how to do a food fraud vulnerability assessment shows the method and scoring if you are building or rebuilding yours.
Five things to do this week
- Check who signed your policy. It should be the person with overall responsibility today, and three staff picked at random should be able to say what it commits the business to.
- List every manufacturer and packer you bought from in the last twelve months, with the approval route for each. Flag any questionnaire used for a product not assessed as low risk and any certificate whose scope does not cover the product you trade.
- List every service provider, from warehouses and hauliers to relabellers and laboratories, and check each has a contract covering incidents, records and subcontracting, and a review in the last twelve months.
- Diarise the next management review and two six-monthly objectives reports, with an agenda built from the required inputs so supplier performance and authenticity are not forgotten.
- Ask for the vulnerability assessment and the date of its last formal review. Check that every product group is in it and that the highest-risk products have a written mitigation plan.
Related course: BRCGS Agents and Brokers Issue 3 for Management
A four-hour, self-paced course for directors, owners and senior managers of trading, import and export, brokerage and agency businesses. Five modules with case studies, knowledge checks and scenario games cover what the Standard expects of senior management personally, the culture plan and management review, supplier and service provider approval, traceability and recall, and how the audit is graded, with a final assessment and an ASC course certificate on passing.
See the BRCGS Agents and Brokers Issue 3 for Management course (4 hours, online, R1,195). Training a team? Choose “EFT or company invoice” at checkout, or WhatsApp us for a quote.
Common questions
Who needs BRCGS Agents and Brokers certification?
Companies that buy, sell or arrange trade in food, packaging, pet food or consumer products without making or processing them: brokers, who take title and resell to businesses, and agents, who facilitate trade without owning the goods. The need is usually set by a customer that wants evidence its supply chain is controlled.
What does senior management have to do personally under Issue 3?
Sign and communicate the policy, define and maintain the product safety and quality culture plan, set objectives and receive progress reports at least every six months, hold a management review at least once a year, keep an escalation route and named deputies, and provide the resources the system needs.
Can we approve overseas suppliers with a questionnaire?
Only for products your risk assessment rates as low risk, with the reasoning written down, and only if someone competent checks and signs off the completed questionnaire. Medium and high-risk products need a valid certificate whose scope covers the product, or a supplier audit with the full report on file. A fresh questionnaire is needed at least every three years.
Does a small trading office really need a culture plan?
Yes. Clause 1.1.2 applies to every company certificated to Issue 3, whatever its size. It needs activities on communication, training, employee feedback and performance measurement, with timescales, measures and a review of what worked. A small office can keep it short, provided every activity is real.
Does Agents and Brokers Issue 3 have fundamental requirements?
No. Unlike the BRCGS Food Safety Standard, Issue 3 marks no clauses as fundamental. Sections with a shaded statement of intent must be met by every certificated company. Bordered sections, such as 4.2 on service providers, may not apply to every business, though 4.2 applies to almost every importer.
Next step. If your leadership team needs a shared view of these duties before committing to a certification date, the BRCGS Agents and Brokers Issue 3 for Management course covers them with South African case studies, and the Introduction to BRCGS for Agents and Brokers Issue 3 course gives buyers, logistics and sales staff the clause-by-clause picture. For the wider BRCGS family, see our BRCGS certification and training hub for South Africa.
This article is general guidance written for South African trading, import, export and brokerage businesses. It is not a substitute for the Standard: a company is audited against the Global Standard for Agents and Brokers (Issue 3) together with any position statements in force, and the Standard requires you to hold a genuine current copy. Before you plan an audit, look on brcgs.com and BRCGS Participate for the latest issue and any position statements. Clause numbers are given so you can navigate your own copy. ASC Food Safety Training is independent of BRCGS: this article and our courses explain the Standard in our own words, are not endorsed by BRCGS, and lead to an ASC course certificate, not a BRCGS qualification.