Gemsbokvlei Foods in Vryburg bakes buttermilk rusks from wheat flour, and since last year it has also made a sorghum and rice flour rusk in a walled-off room in the same building. A national retailer wants to sell the gluten-free rusk under its own label, and its technologist has asked for BRCGS Gluten-Free certification before the first order. The managing director’s plan was simple: send three packs to a laboratory, get results below 20 ppm and ask BRCGS for a gluten-free certificate for the rusks. Almost every part of that plan misreads the scheme. BRCGS Gluten-Free certification is awarded to a site and the gluten-free management system it runs, never to a product. It sits on top of a food safety certificate the site must already hold, or gain in the same audit. And the gluten level a claim has to meet is set by the law of each country the product is sold in, not by BRCGS.
In short
- The BRCGS Global Standard Gluten-Free, Issue 4, was published in February 2024, and audits against it began on 5 August 2024. It certificates the site and its gluten-free management system (GFMS), never a product.
- It is an add-on. Every site must also hold a GFSI-benchmarked food safety certificate, BRCGS START! at Intermediate level or above, or an equivalent. A site without one combines the gluten-free audit with its food safety audit.
- There is no single gluten limit in sections 1 to 7: clause 4.3.1 hands the question to the law of the country of sale. A fixed 20 mg/kg, tested by R5 ELISA, applies only on the optional AOECS Crossed Grain route (section 8).
- A GFMS team leader who has passed the BRCGS Gluten-Free Issue 4 Sites Training course (clause 1.2.3) leads a multidisciplinary team.
- Findings are graded critical, major or minor. There is no site grade and there are no fundamental clauses, and a certificated site is audited every 12 months.
- Corrective action evidence is due within 28 calendar days of the audit, and the certificate follows within 42 calendar days.
What BRCGS Gluten-Free certification is, and what it is not
The Global Standard Gluten-Free began in 2012 as the Gluten-Free Certification Program and is now published by BRCGS, with Issue 4 the current version. Its approach is a system, not a test result: controls stop gluten reaching gluten-free products, and when one fails, the system shows it quickly so the site can contain and fix it. The audit is done by an independent certification body (CB) that BRCGS has approved, and it looks at buildings, records and real working practice.
Buyers care because of the person at the end of the chain. Coeliac disease is an autoimmune condition in which gluten from wheat, rye or barley damages the small intestine. There is no cure, only a strict gluten-free diet for life, so a gluten-free claim is part of someone’s treatment. The Standard’s background appendix puts coeliac disease at about 1.4% of people worldwide and estimates non-coeliac gluten sensitivity at about 6%, and notes that people struggle to choose safely from ingredient lists alone. Certification gives a site a report and certificate many customers accept instead of their own audit, an optional BRCGS Directory listing, and a route to gluten-free trademarks shoppers recognise. AOECS, the umbrella body for around 40 national coeliac societies, works with BRCGS under a collaboration agreement, and Beyond Celiac and Celiac Canada endorse the Standard.
| Common assumption | What the Standard actually says |
|---|---|
| “BRCGS will certify our gluten-free rusks.” | The site and its GFMS are certificated. Where BRCGS-managed trademarks are used, no pack, advert or website may describe the product as certified; any certification claim refers to the site or its system (clause 4.3.3). |
| “20 ppm is the BRCGS limit.” | Sections 1 to 7 set no number. The product must meet the law of the country of sale (clause 4.3.1). 20 mg/kg belongs to the Crossed Grain route. |
| “This replaces our food safety certificate.” | It sits on top of one: a GFSI-benchmarked certificate, START! at Intermediate level or above, or an equivalent. |
| “We can print the BRCGS logo on the pack.” | The BRCGS Gluten-Free logo is for stationery and marketing only, never products or packaging. |
| “We will get an AA, like our Food Safety audit.” | There is no site grade. Each finding is critical, major or minor, and the audit is every 12 months. |
Who it is for, and the food safety certificate you need first
The Standard covers the manufacture, processing and packing of gluten-free products: processed foods under the site’s own brand or a customer’s label, ingredients for other manufacturers, caterers and food service businesses, and three further groups: pet foods, cosmetics and natural health products. It does not cover trading. Wholesale, importing, distribution and storage of food outside the company’s direct control are left to other BRCGS standards.
| Your business | Does Gluten-Free Issue 4 fit? | Why |
|---|---|---|
| A manufacturer of gluten-free products, own brand or a retailer’s label | Yes | Processed foods, own-brand and customer-branded, are the core of the scope. |
| A miller or blender supplying gluten-free flours or mixes to other businesses | Yes | Ingredients for manufacturers, caterers and food service are in scope. |
| A maker of pet food, cosmetics or natural health products | Yes, with trademark limits | Pet foods and cosmetics cannot carry the Crossed Grain Trademark; natural health products must check with the AOECS member society. |
| An importer, wholesaler or distributor that does not make or pack | No | Other BRCGS standards cover trading and storage outside your direct control. |
| A manufacturer with no food safety certificate yet | Yes, but not on its own | The gluten-free audit is combined with the food safety audit. |
The last row matters most. Every site must also be certificated to a GFSI-benchmarked food safety scheme (BRCGS Food Safety and FSSC 22000 are examples), to BRCGS START! at Intermediate level or above, or to an equivalent of START! Intermediate from a GFSI-benchmarked scheme owner, and must have worked through the hazards of every process and product using Codex HACCP principles. With one of those in hand, a standalone gluten-free audit is an option; without one, the gluten-free and food safety audits happen together. If you are still choosing a food safety scheme, our comparison of which food safety certification your business needs is the place to start.
Gemsbokvlei already holds a GFSI-benchmarked certificate, so a standalone audit is open to it. Only two things can be left out of scope: section 8, when the Crossed Grain Trademark is not used or intended, and qualifying off-site storage that the company owns and manages within 50 km. The wheat rusks are not gluten-free products, but the auditor will still look hard at how wheat flour is received, stored and kept away from the sorghum line, because that is where the claim can fail.
What “gluten-free” means: the law of the country of sale decides
In the Standard’s glossary, gluten means the proteins of wheat, rye, barley and oats, and of their crossbreeds and derivatives. Oats count as a gluten source unless they are verifiable gluten-free oats, and verifiable means the site can prove it. The glossary defines a “gluten-free product” by reference to the Standard’s requirements, not to a figure.
The number comes from clause 4.3.1, which ties the gluten content of each finished product to whatever the law of its market demands. A site that sells a rusk at home and exports it to two other countries has to meet the gluten-free rules of all three, and those rules need not match. Give one person the job of confirming the claim rules of every market, South Africa included, and record the answer in the product specification. Our article on why a compliant South African label can fail in an export market shows how quickly those differences add up.
| Situation | Who sets the gluten level | How it is shown |
|---|---|---|
| A gluten-free product under sections 1 to 7 | The law of each country of sale (clause 4.3.1) | A risk-based sampling and testing programme, with internal testing verified yearly by an ISO 17025-accredited laboratory (clauses 4.7.1, 4.7.2) |
| A product carrying the AOECS Crossed Grain Trademark | AOECS: no more than 20 mg/kg, the same as 20 ppm, in the food as sold (clause 8.1.1) | R5 ELISA (Mendez method), or competitive R5 ELISA for fermented or partly hydrolysed gluten (clause 8.6.1) |
| The Standard’s background appendix on coeliac disease | Diet advice: foods below 20 ppm, ideally with none detected | Context only, not a legal or certification limit |
The AOECS Standard behind the Crossed Grain Trademark follows Codex Standard 118-1979 and EU Regulation 828/2014. For Gemsbokvlei, three good laboratory results answered the wrong question. The retailer wants evidence that every batch, on any shift, meets the claim in its market, and only the system can give that.
Trademarks, the Crossed Grain route and the BRCGS logo
Certification and trademarks are separate decisions, and the trademark decision shapes the audit scope, so make it early. Section 8 becomes required where the Crossed Grain Trademark is used or planned, on the site’s own brand or on products made for a brand owner that holds, or is applying for, an AOECS licence; otherwise it can be excluded, and the exclusion is shown on the report and certificate. Using the mark needs all three of these: a site certificated to the Gluten-Free Standard, section 8 included in the audit, and a signed, current licence from the AOECS member society of the country the brand comes from. Where that country has none, the AOECS helpdesk is the contact. Make that contact before booking the audit. Section 8 is never certificated on its own.
| Mark | Who gives permission | What is needed |
|---|---|---|
| BRCGS Gluten-Free logo | BRCGS brand rules | A current certificate. Letterheads, websites and marketing only, never a product or its pack. |
| Informed Gluten-Free, Beyond Celiac, Celiac Canada (BRCGS-managed) | BRCGS | A Brand Programme Agreement, a signed Trademark Approval Form before first use (clause 4.3.2) and a Schedule A signed by BRCGS (section 6). |
| ACELMEX | ACELMEX | ACELMEX permission, with the products on a Schedule A. |
| AOECS Crossed Grain Trademark | The AOECS member society | Section 8 audited and a signed, valid licence contract (clause 8.5.1). |
The Standard positions Informed Gluten-Free for parts of the world without a partner coeliac association, Africa among them, which makes it the probable choice for a South African site wanting a consumer mark. Confirm that with BRCGS before artwork is drawn. Whatever the mark, the wording rule is the same everywhere: the site is certificated, the product is not.
The gluten-free management system and the team that runs it
The GFMS is the output of a HACCP study done to the Standard’s requirements: hazards, critical control points and limits, monitoring, what happens when things go wrong, verification and records. Section 2 wants a HACCP plan, built on Codex principles, in which gluten has its own line in the hazard analysis, supported by prerequisite programmes designed with gluten in mind (clauses 2.1.1 and 2.2.1). The team reviews it every year and, crucially, ahead of any change that might weaken gluten control (clause 2.3.1). If your HACCP team needs to strengthen its hazard analysis first, the HACCP for Supervisors and HACCP Teams course covers the method.
Section 1 makes the system a management responsibility. A senior manager at the site signs and dates a gluten-free policy, renews it every year and whenever someone new takes over that role, and makes sure every employee knows it (clause 1.1.1). Management provides the people, money, buildings and equipment the controls need, names people who can act on problems and enforce the rules on anyone entering the site, and gives the team time to meet (clause 1.1.2). The site holds a genuine copy of the current Standard, follows binding BRCGS position statements (clause 1.1.3) and makes sure the recertification audit happens on or before the due date (clause 1.1.4).
| Role | What the Standard expects | What an auditor will often ask |
|---|---|---|
| Senior management | Signs the policy, provides resources, has a senior manager at one or more team meetings a year, receives escalated issues (1.1, 1.4.2, 1.4.3) | Who signed the policy, and do they still hold the role? |
| GFMS team leader | Authority to run, validate, review and improve the system; in-depth knowledge; has passed the BRCGS Gluten-Free Issue 4 Sites Training course (1.2.1 to 1.2.3) | Appointment letter and the Issue 4 Sites course pass |
| Documented deputy | Covers the team leader’s absence (1.2.1) | Who stands in, and is it written down? |
| Multidisciplinary team | Quality, procurement, product development, hygiene, production and engineering, each knowing the gluten controls (1.3.1, 1.3.2) | Team list, training records and minutes |
| Outside experts | May support the team; the site keeps day-to-day responsibility (1.3.3) | The split of duties in the consultant’s contract |
The right-hand column is our experience. Team meetings happen at least annually, with extra ones after a new product, an incident, a new risk or a change of material, supplier, process or cleaning method, and the minutes record owners and dates (clause 1.4.1). Read clause 1.2.3 carefully: the team leader must have passed BRCGS’s own Gluten-Free Issue 4 Sites Training course, and no awareness course from another provider can stand in for it. Our Introduction to BRCGS Gluten-Free Issue 4 course is built for the rest of the team: supervisors, buyers, hygiene and production staff.
Audit options and what happens on audit day
| Option | How it works | Who can use it |
|---|---|---|
| Standalone announced | Gluten-free clauses only, on a date fixed in advance | Sites that already hold a GFSI-benchmarked, START! Intermediate or equivalent certificate |
| Standalone blended announced | Records reviewed remotely, then an on-site audit | Existing certificated sites, at recertification only |
| Combined announced | Run alongside the food safety audit, date fixed in advance | New and existing sites |
| Combined blended announced | Remote then on-site, combined with food safety | Recertification only |
| Combined unannounced | The CB chooses the date and does not disclose it | All sites, though a new site may wait up to a year for it |
What is available on the combined route depends on your food safety programme, so confirm the options with your CB. Blended audits are never used for a first certificate. Sites on a combined route with a GFSI-benchmarked scheme get at least one unannounced audit in each three-year period; the CB names the year in advance, never the day. A standalone audit typically takes 1.5 to 2 days on site; combined with a food safety audit, the gluten-free element adds half a day.
The day follows a set pattern: an opening meeting, a tour of production and storage that checks hygiene, the flow diagram and changeovers, conversations with staff, a document review, a vertical audit following one batch from intake to finished product with a traceability challenge and mass balance, a label review against specifications, the law and trademark approvals, and a closing meeting. Roughly half the time is spent on the floor. The GFMS team leader or documented deputy must attend both meetings, senior managers who can commit to corrective action are expected there too, and the leader’s absence does not stop the audit. The auditor confirms the findings at the close but does not predict the outcome; the CB’s management decides independently afterwards.
Findings: critical, major and minor, with no site grade
Issue 4 grades each finding, not the site. In plain terms, a critical means gluten control has failed badly or the site has a legal problem. A major means a requirement has largely not been met, or what the auditor saw casts real doubt on whether product leaving the site is what it claims to be. A minor means a requirement is only partly met, with no doubt about the product itself. Repeated minors against one clause may become a major, and several minors on one clause cannot be merged into one.
| Audit result | What happens next |
|---|---|
| No critical or major, 7 minors or fewer; or 1 major and 5 minors or fewer | Evidence of corrective action within 28 calendar days; certificate; 12-month audit frequency |
| No major, 8 to 10 minors; or 1 major and 6 to 8 minors | A revisit within 28 calendar days to check the actions; certificate if satisfactory; still 12 months |
| Any critical; 2 or more majors; 1 major and more than 8 minors; or more than 10 minors | No certificate. A full re-audit by the same CB, no sooner than 28 calendar days later; an existing certificate is withdrawn at once |
For every finding the site corrects the problem, finds the root cause and writes a preventive action plan, and all three reach the CB within 28 calendar days or no certificate is issued. Longer fixes, such as new dust extraction, need only the plan in that time. Our guide to corrective action and root cause analysis for audit findings shows what a CB will accept. The certificate follows within 42 calendar days of the audit, and the report reaches the BRCGS Directory within 49 days of the last audit day. On the standalone route, re-audits then fall in the 28 days before each 12-month due date (a combined audit follows the food safety scheme’s timing), and a late audit without a justifiable reason, such as a natural disaster, earns a major next time.
How to prepare for a first BRCGS Gluten-Free audit
The Standard sets no preparation period. Readiness depends on whether the system has run long enough to leave records that prove it works, and a newly opened site audited less than three months after starting is unlikely to show full compliance. A practical order of work:
- Settle the food safety route and plan a combined audit if the site holds no qualifying certificate.
- Decide on markets and trademarks, and contact the AOECS member society or helpdesk early if the Crossed Grain Trademark is in view.
- Sign the Site Programme Agreement with BRCGS. No audit can go ahead without it; it carries an annual fee and renews automatically.
- Buy a genuine copy of Issue 4, check brcgs.com for position statements, appoint the team leader and deputy, and book the leader onto the BRCGS Issue 4 Sites Training course.
- Run a gap analysis and close the gaps, then choose a BRCGS-approved CB. BRCGS publishes a star rating for each CB in the Directory, and the auditor who does an optional pre-assessment cannot do the certification audit.
Our checklist on how to prepare for a food safety audit in South Africa covers the preparation common to every scheme. For a gluten-free audit, add a walk of the gluten-free line with a supervisor, asking what an auditor would ask about changeovers, line clearance and label checks.
Five things to do this week
- List every market each gluten-free product is sold into and name the person who confirms the claim rules for each, South Africa included.
- Check your food safety certificate route. With no GFSI-benchmarked, START! Intermediate or equivalent certificate, plan a combined audit from the start.
- Decide whether you need a consumer trademark, and which one, before you approach a CB.
- Name the GFMS team leader and deputy in writing, and check whether the leader has passed, or is booked on, the BRCGS Gluten-Free Issue 4 Sites Training course.
- Search your website, brochures and packs for wording that calls a product certified, and for the BRCGS logo on any pack.
Related course: Introduction to BRCGS Gluten-Free Issue 4
A five-hour, self-paced overview of the Global Standard Gluten-Free Issue 4 in three modules and twelve lessons: coeliac disease and what a gluten-free claim rests on, all eight sections of requirements with South African examples, and the certification audit, trademarks and the Directory. Module tests and a 25-question final assessment lead to an ASC course certificate. It is awareness training for the wider team and does not meet clause 1.2.3, which requires the GFMS team leader to pass BRCGS’s own Issue 4 Sites Training course.
See the Introduction to BRCGS Gluten-Free Issue 4 course (5 hours, online, R1,195). Training a team? Choose “EFT or company invoice” at checkout, or WhatsApp us for a quote.
Common questions
What is BRCGS Gluten-Free certification?
It is third-party certification of a manufacturing site against the BRCGS Global Standard Gluten-Free, currently Issue 4. A BRCGS-approved certification body audits the site’s gluten-free management system, from management commitment and a HACCP plan that names gluten as a hazard to supplier approval, contamination control, testing, labelling and training. The site is certificated, not its products.
What gluten level does BRCGS Gluten-Free require?
Sections 1 to 7 set no single figure. Clause 4.3.1 requires the finished product to meet the law of the country where it is sold, so the level depends on the market. A fixed limit of 20 mg/kg, the same as 20 ppm, confirmed by R5 ELISA, applies only to products carrying the AOECS Crossed Grain Trademark under the optional section 8.
Do we need another food safety certificate before a Gluten-Free audit?
Yes. Every site must also be certificated to a GFSI-benchmarked food safety scheme, to BRCGS START! at Intermediate level or above, or to an equivalent. A site that already holds one can choose a standalone gluten-free audit. A site that does not must combine the gluten-free audit with its food safety audit.
Does the Gluten-Free Standard give a grade like AA or A?
No. Issue 4 grades each finding as critical, major or minor, but the site receives no grade and there are no fundamental clauses. One critical, two or more majors, one major with more than eight minors, or more than ten minors means no certificate. A certificated site is audited every 12 months.
Can an ASC course meet clause 1.2.3 for our GFMS team leader?
No. Clause 1.2.3 requires the team leader to have passed BRCGS’s own Global Standard Gluten-Free Issue 4 Sites Training course. Independent awareness courses, including ours, help the wider team understand the Standard but cannot replace that named course.
Next step. If your team needs a shared picture of the Standard before you commit to an audit date, the Introduction to BRCGS Gluten-Free Issue 4 course works through all eight sections and the certification process with South African examples and a test after each module. For the wider BRCGS family, see our BRCGS certification and training hub for South Africa.
This article is general guidance written for South African food manufacturers. It is not a substitute for the Standard: a site is audited against the BRCGS Global Standard Gluten-Free (Issue 4) together with any position statements in force, and the Standard requires the site to hold a genuine current copy. Check brcgs.com for the current issue and position statements before you plan an audit, and confirm the gluten-free claim rules of every market you sell into. 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.