Duikerkop Cold Stores in Kuils River, Cape Town, has kept chilled and frozen food for brand owners for eleven years, with a small reefer fleet delivering across the Western Cape. When a frozen-vegetable brand offered it a three-year contract, the draft came back with one new condition: BRCGS Storage and Distribution certification within nine months. Busisiwe, the managing director, started with three assumptions. The brand owner’s own BRCGS certificate would stretch to cover the cold store. The audit would happen once a year on a date that suited everybody. And the brand’s request for a weekly cross-dock run through a hired bay in Vredenburg could be sorted out later. None survives a first read of the Standard. A Storage and Distribution certificate belongs to one site and the operation it runs, every certificated site gets at least one unannounced audit in each three-year period, and an off-site cross-dock is only covered when the voluntary cross-docking module is in scope.
In short
- The BRCGS Global Standard for Storage and Distribution, Issue 4, was published in November 2020, and audits against it began on 1 May 2021. It is for businesses whose main activity is storing or moving food, packaging and consumer products.
- A certificate covers one site and is issued by an independent, accredited certification body (CB) approved by BRCGS. A customer’s certificate never covers your warehouse.
- Sections 1 to 8 apply to every site, section 9 only where permitted open food is handled, and sections 10 to 19 are voluntary modules, from wholesale and cross-docking to e-commerce and contracted services.
- There are no fundamental clauses. Each sub-section opens with a statement of intent, findings are critical, major or minor, and sites are graded AA to D, with a + after an unannounced audit.
- Under a BRCGS position statement, AA, A and B mean a re-audit every 12 months, C and D every 6 months. Check the current position statements before you plan.
- Every certificated site has at least one unannounced audit in every three years. The CB names the year, never the day.
What BRCGS Storage and Distribution certification is, and what it is not
BRCGS launched its Storage and Distribution Standard in 2006 so that certification could follow products beyond the factory gate, through warehouses, cold stores, depots and vehicles to retail, food service and, for online orders, the consumer. Other BRCGS standards deal with manufacturing food, packaging and consumer goods; this one asks a logistics business whether the safety, legality, quality and integrity of goods stay protected while they are in its hands. Integrity carries two meanings here: the product is genuine, and it reaches the next customer whole.
Three ideas hold Issue 4 together. Leadership owns product safety, and the work is shared by every department that touches stock rather than parked with one quality person. Risks are found through hazard and risk analysis (HARA, or HACCP in food terms) and each is handled by a prerequisite programme, such as pest control, or by a specific control, such as a temperature critical control point. And a documented quality management system turns those decisions into the same practice on every shift. The Standard describes best practice; it does not replace the law, and where legislation is stricter, legislation prevails. Health and safety, environmental and ethical matters are outside it.
| Common assumption | What the Standard actually says |
|---|---|
| “Our customer’s BRCGS certificate covers us.” | Each certificate covers a single site, so a business running five depots needs five, unless the multi-site rules in Part III apply. |
| “BRCGS will come and audit us.” | Independent, accredited CBs approved by BRCGS do the audits. BRCGS oversees them but does not certificate sites itself. |
| “We can print the BRCGS logo on the pallets we handle.” | The logo is for stationery and marketing only, never on products or product packaging (Part III 6.6). |
| “Once certificated, we can relax until the next booked audit.” | Every site has at least one unannounced audit in three years, and the CB or BRCGS may visit a certificated site at any time. |
Who needs it, and why South African customers ask for it
The Standard fits businesses whose main activity is storage and distribution: third-party logistics providers (3PLs), cold stores, distribution centres, hauliers and wholesalers, anywhere in the chain. Eligibility turns on direct management control. A leased warehouse qualifies if the company runs the staff and the quality system itself and can control the building’s condition and services such as pest control. A fleet qualifies if the company manages its vehicles, or the servicing of leased ones, or can show it directly manages contracted vehicles and drivers. Subcontracting is different, because the other firm both provides and manages the service; clause 3.5.2 sets the rules for subcontracted hauliers and stores.
Retailers, food service groups and brand owners ask for certification because an independent report can stand in for their own audit of your site, which saves time and money on both sides. The Standard also gives a recognised benchmark for hygiene, quality and product safety, supports due diligence, and tends to cut damage and waste. Certificated sites can be listed in the BRCGS Directory and use the logo in their marketing. Each customer still makes its own supplier decision.
| Your business | Does Issue 4 fit? | Why |
|---|---|---|
| A 3PL or cold store in a leased building, with its own staff and quality system | Yes | Leasing is fine where you directly manage the operation and the building. |
| A haulier whose customers do all the loading and unloading | Yes, as “transport only” | Loading and unloading are listed as exclusions on the scope. |
| A courier, parcel or pallet network, or a groupage operator | No | Distribution networks are out of scope, except for final-mile delivery under the e-commerce module. |
| A depot that trims or cuts fresh produce before dispatch | No | Processing open food needs the BRCGS Food Safety Standard. |
| An importer or trader with an office but no storage of its own | No | With no product on site, the Agents and Brokers Standard fits. |
Some customers ask for FSSC 22000 instead; our article on FSSC 22000 for transport and storage covers that route, and our comparison of which food safety certification your business needs helps if you are choosing from scratch. Confirm which schemes your main customers accept before you appoint a CB.
Scope: which products and activities can be certificated
Issue 4 was designed mainly for packaged goods, whose packaging shields them from most physical contamination. Food must come in and go out with no further preparation, sorting or processing. Only three kinds of unwrapped food are allowed: fresh fruit and vegetables in open boxes or trays, raw fish and seafood in trays, and whole meat carcasses. Produce trays may be split into smaller orders as long as nothing is cut or trimmed, and bulk foods such as flour, oils, sugar syrups and wine may be stored and moved by road only. Packaging materials and pre-packed consumer goods are covered too. Live animals, bulk or refillable fuels and motor oils, and motor vehicles are excluded completely.
The certificate states the scope in three parts: product categories (chilled, frozen or ambient food, packaging, textiles, electricals and so on), service activities (storage, distribution, transport only, wholesale, e-commerce, cross-docking or a named contracted service) and exclusions, written as “none” where there are none (Part III 1.4.3). Agree that wording with your CB first, because it decides which auditor is sent; auditors are approved by category. Two exclusion rules catch sites out. Parts of the process can never be left out, because a certificate always spans everything from receiving to delivery. Product categories can be excluded only by exception, where they are clearly different and the in-scope goods are kept in a physically separate area, and a site that excludes products may not use the BRCGS logo (Part III 1.4.2). Several buildings count as one site only with one management team, one quality management system and every building within 50 km of where that team is based (Part III 1.5.1).
How Issue 4 is built: statements of intent, not fundamental clauses
Part II holds the requirements in nineteen sections: 1 senior management commitment, 2 hazard and risk analysis, 3 the product safety and quality management system, 4 site and building standards, 5 vehicle operating standards, 6 facility management, 7 good operating practices and 8 personnel, all of which apply to every site; 9 for the handling of permitted open food; and 10 to 19 for the voluntary modules. Each sub-section starts with a statement of intent, the outcome the site must achieve. Managers who know the BRCGS Food Safety Standard often look for a list of fundamental clauses here, and there isn’t one. Falling well short of a statement of intent, or of any single clause, can instead earn a major.
Some clauses carry codes showing when they may not apply: X where the products handled make a clause irrelevant, such as temperature control at an ambient-only site; XS for storage-only operations; XD for distribution-only operations; and XR where a documented risk assessment can justify an exclusion. The auditor, not the site, decides what is not applicable. Every requirement is also coded by where it is assessed, in the facilities and handling practices, in records and systems, or in both, which guides what can be covered remotely in a blended audit. BRCGS also issues binding position statements, collected in a document numbered SD404, and clause 1.1.7 asks every site to hold a current, genuine copy of the Standard and keep up with changes. Our Introduction to BRCGS Storage and Distribution Issue 4 course works through sections 1 to 9 with South African warehouse and transport examples.
The voluntary modules, including cross-docking
Modules let a site add services its customers want certificated in the same audit. They are voluntary and only ever certificated with the main Standard. A module activity the site carries out but leaves out of scope appears on the certificate and report as a stated exclusion, and contracted services that handle product are limited to pre-packed food and finished, fully assembled consumer goods.
| Module | Who it is for | What it adds |
|---|---|---|
| 10 Wholesale | Businesses that buy, own and resell goods to other businesses | Traceability one step back and one step forward, recall tests, supplier approval, and controls on own-label lines |
| 11 Cross-docking | Sites running, or tied by contract to, cross-docks away from the main site | Main-site control of each cross-dock, internal audits, traceability and handling rules |
| 12 E-commerce | Online sellers that pick and pack each order in their own warehouse | Customer agreements, accurate online product information, order traceability, validated shipping packs |
| 13 to 19 Contracted services | Inspection, repacking, quantity control, contract chilling or freezing, container cleaning, waste recovery | Section 13 contract terms plus the section for each service |
Cross-docking needs a closer look, because many distributors do it without using the word. In this Standard a cross-dock means a location separate from the main certificated site at which inbound loads are broken down, sorted and reloaded onto outbound vehicles without being put away into storage locations. Cross-docking inside the main site is already part of the normal audit; an off-site cross-dock, run by the company or tied to it by contract, needs section 11. The main site issues and controls the documents the cross-dock works to (clause 11.1.2), audits each cross-dock internally at least once a year (clause 11.1.3), and makes sure each can trace product through its dock, vehicles and returns included, within 4 hours, in a test run at least yearly (clauses 11.2.1 to 11.2.3).
Facilities that pass are listed on a cross-docking annex issued with the main certificate. Cross-dock audits are always announced, even for a site on an unannounced programme, and follow the main site’s audit. Parcel, courier and pallet-network hubs cannot be added, and nor can repacking at the cross-dock. For Duikerkop, the Vredenburg bay would mean adding section 11, auditing it from Kuils River and writing handling and temperature instructions for the bay staff.
Audit options: announced, blended and unannounced
| Option | How it works | Who can use it |
|---|---|---|
| Announced Option 1 | The whole Standard in one visit on an agreed date; the mandatory unannounced audit replaces it at least once every three years | New and existing sites |
| Announced Option 2 (blended) | A remote review of documents and records, then an on-site audit | Recertification only, after a CB risk assessment, if both sides agree |
| Unannounced Option 1 | One full audit on a date the site is not told | Existing certificated sites |
| Unannounced Option 2 | Part 1 unannounced (site and vehicle practices), Part 2 planned (documents and records) | Existing certificated sites |
In a blended audit the remote part never takes more than half of the total audit time, the on-site part follows within 28 days and inside the due window, and handling practices, the HARA working in practice and the traceability test are always seen in person. Findings from both parts are added together for the grade. Some sites choose an unannounced programme because customers may read it as a sign of a mature system.
An audit lasts at least one day on site, plus about half a day for the report, with the length set by the CB using the BRCGS audit duration calculator (Part III 2.2). It runs from an opening meeting through a review of the HARA and quality system, a site inspection with staff interviews, a vehicle check and a traceability exercise following one product through every linked record, to a closing meeting. The most senior operational manager on site attends the opening and closing meetings (clause 1.1.8). The CB’s management, not the auditor, takes the certification decision.
The unannounced audit every site must plan for
Even on the announced programme, every certificated site must have at least one unannounced audit in each three-year period, and it replaces the normal announced audit that year. Within 3 months of the previous audit the CB tells the site which year it will happen, never the date, and the visit falls in the last 4 months before the audit due date, during normal operations (Part III 2.1.3). A site can name up to 10 days on which an audit really cannot take place, or 5 if it is on a six-month cycle, with dates and reasons given at least 4 weeks ahead; days when the site is not operating must be notified but do not count (Part III 2.1.4). A BRCGS position statement applies the same window and allowance to the voluntary Unannounced Option 1, so check the current position statements before relying on these figures.
When the auditor arrives, the site inspection must start within 30 minutes. A manager on leave is no reason to stop: a nominated deputy runs the meetings, and the technical manager’s absence does not halt the audit (Part III 2.8.5). Refusing entry is far worse than a poor result: certification is suspended until a new unannounced audit, which may come up to 4 months later, and the site normally pays for the wasted visit. For Busisiwe, being always ready means a gate card telling the night guard who to call, a briefed deputy for every key role, and the visitor details a CB needs before any unannounced visit: directions, parking, who to ask for, protective clothing and security procedures. The grade from an unannounced audit carries a plus sign, such as A+.
Findings, grades and how often you are audited
A critical non-conformity is a critical failure on a product safety or legal matter. A major means the site has fallen well short of a statement of intent or a clause, or that the evidence gives real reason to doubt whether the product or service conforms. A minor is a requirement only partly met, with no doubt cast on the product. Minors raised repeatedly against one clause can become a major, and several minors may not be bundled into one. The grade follows from the count.
| Findings at the audit | Grade | What happens next | Re-audit |
|---|---|---|---|
| No majors and up to 5 minors | AA / AA+ | Evidence within 28 calendar days (90 after an initial audit) | 12 months |
| No majors and 6 to 10 minors | A / A+ | As above | 12 months |
| No majors and 11 to 16 minors, or 1 major and up to 10 | B / B+ | As above | 12 months |
| No majors and 17 to 24 minors, 1 major and 11 to 16, or 2 majors and up to 10 | C / C+ | Evidence within 28 days; a revisit where two majors were raised | 6 months |
| No majors and 25 to 30 minors, 1 major and 17 to 24, or 2 majors and 11 to 16 | D / D+ | Revisit within 28 calendar days | 6 months |
| Any critical, 3 or more majors, or more minors than the D bands allow | Not certificated | Full re-audit no sooner than 28 days; a current certificate is withdrawn at once | – |
The printed Issue 4 gave some consumer-products-only sites a longer interval, but a BRCGS position statement removed that concession, so AA, A and B now mean a re-audit every 12 months and C and D every 6 months for every site. The first re-audit after an initial audit always falls within 12 months of the initial audit date. Announced audits take place in the 28 days up to and including the due date, which stays anchored to the anniversary even when an unannounced audit came earlier. A late audit without a justifiable reason, such as a natural disaster that stops the visit, earns a major at the next audit (clause 1.1.10); building work and staff shortages do not count. Confirm the current rules in SD404 on brcgs.com before you plan a cycle.
For every finding the site fixes the immediate problem, finds the root cause and plans preventive action; without evidence in time, no certificate is issued. Our guide to corrective action and root cause analysis for audit findings shows what a CB accepts. The report and certificate typically follow within 42 calendar days (104 after an initial audit). Every site gets a seven-digit BRCGS site code at its first audit, customers can check certificates on brcgsdirectory.com, and reports can be shared with them through the Directory. The logo may go on letterheads, websites and vehicle livery of a site with no product exclusions, never on products or packaging, and its use stops if certification expires, is suspended or is withdrawn (clause 1.1.12; Part III 6.6).
How to prepare for a first Storage and Distribution audit
The Standard sets no fixed preparation period, but a site audited less than 3 months after it starts operating is unlikely to show full compliance, because its system has not yet produced the records that prove it works. A practical order of work:
- Confirm the current issue and position statements on brcgs.com and buy a genuine copy of the Standard (clause 1.1.7).
- Settle the scope: product categories, activities, modules and exclusions, including how cross-docks, overflow stores and subcontracted hauliers are handled.
- Self-assess against every clause and close the gaps, making sure the HARA team has met, the internal audit programme is under way, and the trace and recall tests have each been run.
- Choose a BRCGS-approved CB. BRCGS publishes a star rating for each CB in the Directory; an optional pre-assessment is allowed, but the CB cannot also be your consultant.
- Send the CB what it needs to plan, such as the flow diagram, site plan, organisation chart, shift patterns and vehicle numbers, then agree the date.
Read the CB contract before signing: reports go to BRCGS, witnessed audits must be allowed, BRCGS may visit, and neither the report nor the certificate counts until the CB’s fees and the BRCGS fee have both been paid. Our checklist on how to prepare for a food safety audit in South Africa covers the preparation common to every scheme. For the floor checks an auditor usually makes first, from goods-in and temperature records to vehicles and recall tests, see what a warehouse food safety audit looks at first.
Five things to do this week
- List every building, cross-dock, overflow store and haulier you use, and mark which you directly manage and which are subcontracted.
- Draft your scope in three parts (product categories, activities, exclusions) and check it against your customer contracts.
- Ask your main customers when they need the certificate, and allow at least 3 months of running records before any audit date.
- Name a deputy for every key role and tell the night-shift gate who to call if an auditor arrives unannounced.
- Check your logo plans: letterheads, website and vehicle livery only once certificated with no product exclusions, and never on products or packaging.
Related course: Introduction to BRCGS Storage and Distribution Issue 4
A five-hour, self-paced overview of the Global Standard for Storage and Distribution Issue 4 in three modules and twelve lessons: what the Standard covers and how it is built, the requirements of sections 1 to 9 with South African warehouse and transport examples, and the certification audit, grades and Directory. Module tests and a 25-question final assessment lead to an ASC course certificate.
See the Introduction to BRCGS Storage and Distribution 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 Storage and Distribution certification?
It is independent certification of a warehouse, cold store, depot or transport operation against the BRCGS Global Standard for Storage and Distribution, currently Issue 4. An accredited, BRCGS-approved certification body audits whether goods stay safe, legal, genuine and of the right quality while stored and moved. Each certificate covers one site, not the products it holds.
Does a cold store need its own certificate if its customers are BRCGS certificated?
Yes, if its customers want the cold store itself certificated. Certificates are site-specific, so a manufacturer’s certificate covers only the manufacturer’s site, and a company with several depots needs one for each unless the multi-site rules in Part III apply.
How often is a BRCGS Storage and Distribution site audited?
Under the current BRCGS position statement, sites graded AA, A or B are re-audited every 12 months and sites graded C or D every 6 months. The first re-audit after an initial audit is always within 12 months, and every site has at least one unannounced audit in every three years. Check the current position statements on brcgs.com.
Does BRCGS Storage and Distribution Issue 4 have fundamental clauses?
No. Issue 4 designates no fundamental clauses. Every sub-section begins with a statement of intent that all sites must achieve, and falling well short of one, or of any clause, can be graded as a major. Any critical, or three or more majors, means no certificate.
What is the BRCGS cross-docking module?
Section 11 is a voluntary module for cross-docks located away from the main certificated site, where loads are broken down, sorted and reloaded without going into storage. The main site controls each cross-dock’s documents, audits each one at least once a year and tests traceability through it. Facilities that pass are listed on an annex to the main certificate.
Next step. If your managers and supervisors need a shared picture of the Standard before you commit to an audit date, the Introduction to BRCGS Storage and Distribution Issue 4 course covers scope, sections 1 to 9 and the certification process, with 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 for South African warehousing, cold storage, transport and distribution businesses. It is not a substitute for the Standard: a site is audited against the BRCGS Global Standard for Storage and Distribution (Issue 4) together with any position statements in force. Check brcgs.com for the current issue and position statements before you plan an audit, and check which registrations, approvals and licences the law requires for your premises and vehicles. 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.