BRCGS Plant-Based certification explained: Schedule A, the audit and how to prepare

A pie and samoosa maker in Pinetown already holds an FSSC 22000 certificate and runs its vegetable range on the same lines as its chicken and mutton products. A buyer in the United Kingdom asks whether the frozen vegetable samoosas can carry the BRCGS plant-based mark, and the technical manager assumes it is a form, a fee and a logo file. It is not. The buyer is asking for a second certification that sits on top of the food safety certificate the site already holds, with its own approved product list, its own named specialist on the HACCP team and its own audit, decided as a plain pass or fail. BRCGS Plant-Based certification is an audited management system for keeping material of animal origin out of products sold as plant-based, and the site has to show it working before the mark goes on a single box.

In short

  • The Plant-Based Global Standard, Issue 1 was published by BRCGS in January 2020. It controls one thing only: animal inputs into products sold as plant-based. It is not a food safety, allergen, gluten-free or organic standard.
  • It is an add-on. The site must hold a GFSI-benchmarked food safety certificate or BRCGS START! at intermediate level, or gain one at the same audit. Fail that, and the plant-based certificate is not granted either.
  • Part II has 20 sections and 40 clauses. None is marked fundamental, and there are no grades: the result is certified or not certified.
  • Only products on a Schedule A that BRCGS has approved and that is less than a year old may carry the plant-based trademark.
  • A qualified individual oversees the system: someone with in-depth Codex HACCP knowledge who has passed BRCGS’s own Plant-Based site training course and sits on the HACCP team.
  • A standalone audit takes about one day, or roughly half a day extra when combined with the food safety audit. Audits are every 12 months, booked while plant-based product is being made.
  • Corrective action evidence is due within 28 calendar days, and the report and certificate follow within 42 calendar days of the last audit day.

What BRCGS Plant-Based certification is, and what it is not

BRCGS wrote the Standard because demand for plant-based food was growing fast and manufacturers needed a way to meet it without putting their brands at risk. It is deliberately narrow: a management system for controlling animal inputs, plus the operating rules that go with it. The logic behind the on-pack mark is that animal-derived materials are hard to spot from a label, even for a careful shopper, so a trademark backed by an audited system lets consumers choose quickly.

It covers the manufacture, processing and packing of processed foods (own brand or a customer’s), ingredients sold to food service, caterers and other manufacturers, natural health products such as vitamins, herbal remedies and probiotics, and pet food where the site’s food safety scheme is GFSI-benchmarked. A site of any size can take part. Storage-only businesses, agents, brokers and retailers are not named in the scope, so ask a certification body before planning anything if that is your business.

What the certificate tells a buyerWhat it does not tell them
Animal inputs into the listed products are controlled by a management system an approved auditor has assessed.That the food is safe. That is the job of the GFSI or START! certificate underneath it.
The product is on the site’s current, BRCGS-approved Schedule A.That the product is allergen-free, gluten-free or organic, or anything about ethics such as animal testing.
Suppliers, goods-in, recipes, rework, labels and claims are managed with animal-origin material in mind.That animal-derived traces sit below a set limit. The Standard sets no numeric limit or detection threshold.

How it sits on top of your GFSI-benchmarked certificate or BRCGS START!

The Standard assumes the basics of food safety are already in place. Before any plant-based clause is assessed, the site must run prerequisite programmes suited to safe, legal food and a full Codex-based hazard analysis covering all its products and processes. It must also be certified to a GFSI-benchmarked scheme, such as FSSC 22000 or the BRCGS Global Standard Food Safety, or to BRCGS START! at intermediate level or an equivalent global markets programme from a GFSI-benchmarked standard owner. The two certificates can be earned at one combined audit, but the plant-based one depends on the other: if the food safety certificate is not achieved, plant-based certification is not granted either. The GFSI recognition buyers look for comes from the food safety certificate, so present the plant-based certificate as an add-on to it.

Your starting positionRoute open to youWhat to watch
Certified to FSSC 22000, BRCGS Food Safety or another GFSI-benchmarked schemeStandalone plant-based audit, or combined with your next food safety auditA combined audit follows the GFSI scheme’s re-audit dates, so plan around that due date.
Certified to BRCGS START! at intermediate levelStandalone or combinedPet food needs a GFSI-benchmarked scheme underneath, so confirm eligibility with your certification body first.
No food safety certification yetCombined audit only, gaining both certificates togetherIf the food safety certificate is not achieved, neither certificate is issued.

The product category on the plant-based audit follows the food safety scheme, so the certification body can send an auditor who knows your products. If you are still choosing that scheme, our comparison of which food safety certification suits which business sets out the options for South African sites.

What “plant-based” means under the Standard

The definition turns on intent and reaches well past the ingredient list. A product is plant-based when no material of animal origin has been put into it on purpose, and none has been used on purpose to make it, at any stage of production. That takes in additives, carriers, flavourings, enzymes and processing aids, even those that leave nothing measurable behind. A clear juice fined with gelatine fails the test even if no gelatine can be found in the bottle.

Material of animal origin means anything that comes from an animal or is produced by one. Milk, eggs, honey, beeswax and shellac all count although no animal is slaughtered, and insects are animals, so a cochineal red is out. Appendix 4 of the Standard lists common examples by group. Many entries, such as glycerol, stearic acid, some amino acids and vitamin D, can come from plants or animals, so treat the list as a prompt to check the source, not a list of banned names.

Accidental cross-contact is outside the definition but not ignored: the HACCP plan (2.1), supplier approval (section 6), cross-contamination control (17.1) and recall notification (12.1) all deal with it. The Standard sets no detection threshold and does not say whether a product with a precautionary “may contain milk” statement can carry the mark, so put that question to your certification body in writing before you finalise artwork.

Schedule A and the plant-based trademark

Schedule A is the list of every plant-based product made at the site that you want recognised and labelled with the trademark. Clause 1.2 requires a current Schedule A that BRCGS has approved and that is less than a year old, and the auditor compares it with what is being made, packed and labelled on the day. Submitting it is one of the first steps towards certification. The Standard has no separate scope-extension procedure, so ask your certification body how a new product is added between audits and whether that triggers a visit.

The trademark is a licence, not a logo you own. It may appear only on Schedule A products, and every use of the Standard’s name or mark, on pack, in advertising or on social media, must be approved by BRCGS, follow the plant-based trademark usage guide and comply with the law of the country of sale (16.1). Superseded packaging carrying the mark is controlled as obsolete material (19.1), and if certification is suspended or withdrawn, all use of the mark stops.

Schedule A also works for buying. Where a supplier holds a Plant-Based certificate, check that your ingredient is on its Schedule A. A co-manufacturer making plant-based product for you must be certified with your product on its Schedule A, with no alternative route (6.2, 6.5).

The qualified individual: who oversees the system

Clause 1.3 asks senior management to build the plant-based management system (PBMS) into the site’s wider system: the policy, the organisation chart, management review and resourcing, with a suitably trained qualified individual appointed to oversee it. The glossary sets three conditions: in-depth knowledge of Codex HACCP principles or an equivalent, a pass on BRCGS’s own Plant-Based Global Standard site training course, and membership of the HACCP team.

The role carries real authority. The qualified individual, or a designate, reviews and verifies supplier questionnaires on animal-origin control (6.2), and with the HACCP team formally approves every new plant-based product and every change to recipe, packaging or process before it enters the factory (13.2). It makes sense to involve them in label approval too. On most South African sites the natural candidate is the HACCP team leader or QA manager, provided they have the standing to stop a supplier, a launch or a run. If the HACCP grounding needs work first, the HACCP for Supervisors and HACCP Teams course covers it. Our Introduction to BRCGS Plant-Based Issue 1 course is useful background for the qualified individual and the wider team, but it is independent awareness training and does not replace the BRCGS site training course the definition requires.

The 20 sections of requirements in plain language

Part II holds the auditable requirements: 20 short sections with 40 clauses between them, none marked fundamental. Much of it will feel familiar to a GFSI-certified site. The difference is the lens: each system is pointed at whether anything of animal origin could reach a product sold as plant-based.

SectionWhat the site has to show
1 Senior management commitmentA current copy of the Standard, an approved Schedule A under a year old, and the PBMS built into policy, structure, review and resources.
2 Food safety plan (HACCP)A Codex-based HACCP plan whose hazard analysis covers animal-origin contamination.
3 PBMS reviewAt least yearly, and before any change to ingredients, suppliers, recipes, equipment, packaging or volumes.
4 Documents and recordsVersion-controlled PBMS documents, secure backed-up files, records an auditor can follow.
5 Internal auditsPBMS activities in the programme, frequency by risk, each audited at least once a year.
6 Suppliers and ingredientsA risk assessment of every ingredient and input, hidden sources included, reviewed at least every three years; two approval routes; certified co-manufacturers only.
7 Receipt and acceptanceRisk-based goods-in checks, batch-specific certificates of analysis from accredited labs where testing is needed, current versions only.
8 Service suppliersPest control, laundry, cleaning, maintenance, haulage, storage, labs and waste assessed for plant-based risk and covered in contracts.
9 SpecificationsIngredient, input and finished product specifications stating freedom from animal-origin material, reviewed at least every three years.
10 TraceabilityA yearly test on a plant-based product, both directions, with a mass balance.
11 ComplaintsEvery complaint recorded; substantiated ones investigated to root cause.
12 Recall and withdrawalCertification body told within 24 hours of the official notice when animal-origin contamination is the cause.
13 Product developmentRules restricting animal-origin materials; HACCP team and qualified individual sign-off before anything reaches the factory.
14 LabelsApproval, re-approval after formulation changes, accurate information to customers who control their own labels.
15 AuthenticityHorizon scanning and a yearly vulnerability assessment for substitution with animal-origin material.
16 Marketing claimsEvery use of the Standard or mark approved by BRCGS and lawful where sold; other animal-free claims defined and approved.
17 Cross-contaminationRisk-based controls on scheduling, people, storage, tools, PPE, airflow and cleaning between runs.
18 Recipes and reworkWeighing and mixing controls, rework rules, labelled ingredients and work in progress.
19 Obsolete materialsSuperseded packaging, ingredients and product segregated and disposed of safely.
20 Awareness trainingAll relevant people, including engineers, temps and contractors, trained at least yearly.

Two sections behave like miniature versions of systems you may already run. Section 6 approves suppliers either through a valid Plant-Based certificate with the ingredient on the supplier’s Schedule A, or through all three of a questionnaire verified by the qualified individual, an agreed specification and a written guarantee of no blend changes without your approval. Section 15 is food fraud vulnerability assessment with one specific question, and our guide on how to do a food fraud vulnerability assessment shows the method. The floor-level controls in sections 7, 17, 18 and 19 are covered in our companion guide to hidden animal ingredients and plant-based cross-contamination.

Audit options and what happens on audit day

There are three ways to be audited. Whichever you choose, book the audit for a time when plant-based product is actually running, because the auditor needs to see the controls working, including a changeover.

Audit optionHow it worksWho it suits
StandalonePlant-based requirements only, typically about one day on site.Sites already holding a GFSI-benchmarked certificate or START! intermediate.
CombinedAudited alongside the GFSI or START! audit, adding roughly half a day.Sites gaining both certificates together, or wanting one visit a year.
Unannounced combinedThe food safety audit is unannounced. If no plant-based product is running, the auditor walks the process and reviews earlier records, and the next audit must see production.Established sites only. The walk-through is not allowed for a first plant-based audit.

Choose a certification body from the approved list on the BRCGS Directory, where each carries a performance star rating, and check first that your customers accept it. On the day expect an opening meeting, a review of the PBMS and HACCP plan, a production inspection, a traceability challenge, a review of sampled labels against specifications and the law, and a closing meeting where a draft list of non-conformities is left with you. The weight falls on practice: the auditor will spend much of the day on the floor, watching changeovers and reading records with the people who keep them. You may decline a particular auditor, and no auditor may audit the same site more than three times in a row. Our guide to preparing for a food safety audit in South Africa applies here too.

Non-conformities and the certification decision: pass or fail, no grades

This is where sites carry assumptions across from the BRCGS Food Safety Standard that do not apply. The Plant-Based Standard defines no critical, major or minor categories, no points, no grading scale and no fundamental clauses. The outcome is certified or not certified, so do not plan around an AA or a B.

Each non-conformity needs a correction, a root cause analysis and a preventive action, in a dated plan sent to the certification body. You close findings with objective evidence such as revised procedures, records, photographs or invoices, or through a further visit. If satisfactory evidence has not arrived within 28 calendar days of the audit, certification is not granted and another full audit may be needed. No certificate is issued until every non-conformity is addressed.

The auditor does not make the decision. A technical reviewer at the certification body reviews the report and your evidence and decides independently. If the findings rule out certification, the site needs another full audit no sooner than 28 days after the first, and a site that already holds the certificate loses it immediately. All fees due to BRCGS must be paid before the certificate and report become valid, whatever the outcome.

EventTimescale
Corrective action evidence to the certification bodyWithin 28 calendar days of the audit
Certification body review of that evidenceWithin 14 days
Audit report and certificateWithin 42 calendar days of the last audit day
Re-audit after an audit that rules out certificationNo sooner than 28 days after the audit
Recertification auditEvery 12 months, in a 28-day window ending on the due date (combined audits follow the GFSI scheme’s dates)
Recall notification for animal-origin contaminationWithin 24 hours of the official notice
Schedule ABRCGS-approved and under a year old

The certificate shows a re-audit window and an expiry date; confirm with your certification body how both are calculated for your site. Certification can be suspended between audits, for example for non-compliance with the Standard or the law, a risk to public health or plant-based status, or unpaid BRCGS fees, and withdrawn where corrective measures are not completed or false information is given. Either way, every use of the mark stops. What a failed claim can cost the business, and how managers plan a realistic route to the audit, is covered in our guide to plant-based claim risk and the certification audit.

How long it takes, and how to prepare

The Standard gives one readiness figure: a new site is unlikely to show full compliance less than three months after it starts operating. For an established site the limit is evidence rather than writing. The PBMS review, internal audit coverage, the traceability test, the vulnerability assessment and awareness training all run yearly, so expect the auditor to look for evidence that each has been done at least once. The Standard expects a preliminary self-assessment, with the gaps closed, before the audit; BRCGS publishes a self-assessment tool to help. For a GFSI-certified site a sensible order is:

  1. Decide the range and the route, standalone or combined, and the certification body your customers accept. Draft and submit Schedule A.
  2. Appoint the qualified individual and book BRCGS’s site training course early.
  3. Extend the HACCP study and risk assessment to every ingredient and input, including processing aids, lubricants, packaging and cleaning chemicals.
  4. Rebuild supplier files by one of the two routes, emergency suppliers included.
  5. Put the floor controls in place: scheduling, verified changeover cleans, dedicated or colour-coded tools and PPE, segregated storage, rework rules and obsolete packaging control.
  6. Run each yearly activity once, then book the audit for a day when plant-based product is running.

Five things to do this week

  1. List the products you want to carry the mark, with current recipes and artwork. That is the first draft of Schedule A.
  2. Confirm your food safety certificate covers the same site and products, and note its re-audit date, which a combined audit will follow.
  3. Check your proposed qualified individual against the definition: HACCP depth, HACCP team membership and a place on BRCGS’s site training course.
  4. Pull ten raw material specifications at random and look for an animal-origin statement covering carriers, processing aids and sub-ingredients. The gaps are your supplier workload.
  5. Ask two certification bodies about timing and cost, after confirming which bodies your customers accept.

Related course: Introduction to BRCGS Plant-Based Issue 1

A five-hour, self-paced overview of the Plant-Based Global Standard in three modules and twelve lessons: what plant-based means, where animal-derived material hides, all 20 sections in plain language, and the certification process from Schedule A to the certificate. It is independent awareness training and does not replace BRCGS’s own site training course for the qualified individual.

See the Introduction to BRCGS Plant-Based Issue 1 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 Plant-Based certification?

It is an add-on certification from BRCGS for manufacturers whose products are sold as plant-based. An approved auditor checks that the site runs a management system keeping material of animal origin out of the products listed on its approved Schedule A. Certified sites may use the BRCGS plant-based trademark on those products, with BRCGS approval for each use.

Do we need a GFSI-benchmarked certificate first?

You need one, but not necessarily first. The site must hold a GFSI-benchmarked food safety certificate or BRCGS START! at intermediate level, or gain it at the same combined audit. A standalone plant-based audit is only open to sites already holding that certificate, and if the food safety certification is not achieved, the plant-based certificate is not granted.

Is BRCGS Plant-Based the same as a vegan certification?

No. It certifies a plant-based claim under the Standard’s own definition: no intentional use of animal-origin material at any stage of production. Where the certificate backs a different animal-free or meat-free claim or mark, clause 16.2 asks for a written definition of the claim, a contract with any outside mark owner and approval for each product.

What is Schedule A?

Schedule A is the list of plant-based products made at your site that you want recognised under the Standard. BRCGS must approve it, it must be less than a year old, and only products on it may carry the plant-based trademark. You update it as your range changes.

Who can be the qualified individual?

Someone with in-depth knowledge of Codex HACCP principles who has passed BRCGS’s Plant-Based Global Standard site training course and sits on the site’s HACCP team. Independent awareness courses, including ASC’s, are useful background but do not replace that BRCGS course.

Does BRCGS Plant-Based have grades like AA or B?

No. The Standard defines no grades, no critical, major or minor categories and no fundamental clauses. The result is certified or not certified. Every non-conformity must be closed with evidence within 28 calendar days of the audit, or the certificate is not granted.

Next step. If your team needs a shared understanding of the Standard before you start, the Introduction to BRCGS Plant-Based Issue 1 course covers every section, the floor-level controls and the audit, with a knowledge test after each module and a certificate of completion. For the wider BRCGS family and the courses that support it, 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 Plant-Based Global Standard (Issue 1) together with any position statements in force, and the Standard requires the site to keep a current copy. Check brcgs.com that Issue 1 is still the current issue before you plan an audit. Clause numbers are given so you can navigate your own copy. ASC Food Safety Training is independent of BRCGS, and this article is not endorsed by BRCGS.

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