Kwaggasdrift Foods in Delmas, Mpumalanga, makes gluten-free maize and sorghum pasta under its own brand and under a national retailer’s label that carries the Informed Gluten-Free mark. It has held BRCGS Gluten-Free certification for two years, and its next audit is five weeks away. On a Thursday afternoon the laboratory reported a result above the retailer’s specification on a batch of gluten-free fusilli that had left for the retailer’s distribution centre two days earlier. On Friday the retailer forwarded a shopper’s complaint of stomach cramps after eating fusilli from an earlier batch. Kabelo, the commercial director, asked what this would cost. Elmarie, the QA manager and team leader of the gluten-free management system (GFMS), answered with a list: the stock, a withdrawal or recall, notifications to three organisations, one within 24 hours, a retailer wanting answers before its range review, a trademark that depends on the certificate, and an audit that could not move. Themba, the operations director, asked whether the audit could at least be pushed back a month. Only at a price of its own. That is gluten-free claim risk in practice.
In short
- A gluten-free claim usually fails in one of four ways: a high test result, a complaint reporting a reaction, the wrong pack or label, or wording and marks used without permission.
- When a gluten-free product is withdrawn or recalled, the national competent authority, the certification body (CB) and BRCGS are told: BRCGS within 24 hours of the official notice, and the CB gets root cause and preventive action within 21 calendar days (clause 3.8.1).
- After an incident the CB can confirm, suspend or withdraw the certificate, and the BRCGS logo and BRCGS-managed trademarks follow its status.
- At a BRCGS Gluten-Free audit every finding is rated critical, major or minor, and the totals are read against Table 1. The site gets no grade, and certificated sites return to audit every 12 months.
- Each finding needs its evidence, root cause and preventive plan with the CB inside 28 calendar days; without them there is no certificate.
- A recertification audit held late without an accepted reason becomes a major at the next audit; staff shortages and building work are not accepted reasons.
Gluten-free claim risk: what is exposed when a claim fails
A gluten-free claim is a promise to someone who cannot check it. The only treatment for coeliac disease is a strict gluten-free diet, and the Standard’s background appendix notes that shoppers struggle to spot gluten-containing ingredients on a label, so an explicit gluten-free statement carries real weight. When the promise fails, the cost does not stop at the batch. Several assets are exposed at once, each held by a different party.
Certification covers the site and its GFMS, not a product, so each pack’s claim stands alone against the law of the country of sale (clause 4.3.1) and the customer’s specification. A certificate cannot rescue a failed claim, but a failed claim can sink a certificate. The decisions that keep a claim safe in the first place, from the signed policy to supplier approval and testing budgets, are covered in our guide to BRCGS Gluten-Free management responsibilities.
| What is exposed | Who controls it | How it is lost |
|---|---|---|
| The claim on the pack | The law of the country of sale; the customer | A result or complaint showing it is not met (4.3.1) |
| The customer listing | Your customer, under contract | Lost confidence after an incident or a lapse |
| The certificate | The certification body (CB), which owns it | Suspension or withdrawal (Part III 5.1.1, 5.4) |
| BRCGS-managed marks such as Informed Gluten-Free | BRCGS | Use stops when certification stops (Part III 5.8) |
| A Crossed Grain licence | The AOECS member society and brand owner | They judge what an incident means for it (Part III 4.10) |
| The Directory listing | The CB records your status | A lapse shows, and everyone you share with is emailed (Part III 5.9) |
Four ways a gluten-free claim fails
Most failed claims arrive through one of four doors. Our article on gluten cross-contact maps how gluten physically gets into product; this table takes the commercial view.
| How it shows up | Typical system cause | What it sets in motion | Clauses |
|---|---|---|---|
| A result above specification | An unvalidated clean, an unapproved supplier, misplaced rework | Hold, trace, then withdraw or recall if product has left | 3.2.2, 3.8.1 |
| A complaint reporting a reaction | Any of the above, found weeks later | Investigation; CB and BRCGS told once substantiated | 3.7.1, 3.7.2 |
| The wrong pack or label | Old film, a missed line clearance, an untested scanner | A labelling incident, often a withdrawal or recall | 4.6.1, 5 |
| Wording or a mark misused | “Certified” beside a product, a mark used before approval | Referral by BRCGS and a risk to the certificate | 4.3.2, 4.3.3 |
A fifth, administrative failure, a lapse because an audit or deadline slipped, is covered below.
The first 48 hours after a high result
A high gluten result is a management decision before it is a laboratory one, and Elmarie worked in a fixed order. Contain: hold everything that might be affected, on site and, where possible, in transit. Establish the facts: follow the batch out to every customer and back to each raw material lot, and balance the quantities so you know what was made, what you still control and where the rest went. Question the number: does the method suit this product, and which limit is it measured against? That is the law where the product is sold, a stricter customer figure if there is one, or, only on Crossed Grain products, 20 mg/kg (the same as 20 ppm). Log the deviation and each step taken (clause 3.2.2), and put the result on the GFMS team’s agenda as a reason to review the system (clauses 1.4.1, 2.3.1).
Then comes the costliest decision. In the Standard’s glossary a withdrawal brings product back from customers but not consumers, normally where consumers face no risk because stock has not reached the shelf; a recall reaches consumers. Kwaggasdrift’s fusilli was still in the distribution centre, so a withdrawal was possible once the retailer confirmed none had gone to stores. The complaint concerned an earlier batch, so retained samples went for testing that day and the trace widened to the whole week’s production. Decide in advance who may call a withdrawal or recall, who stands in at night, and how a brand owner takes part when the product carries its label.
Look for the gap in the system, not a person to blame. At Kwaggasdrift it sat in purchasing: sorghum flour had arrived from an approved supplier’s second mill, while its Gluten-Free certificate covered only the first, and approval by certificate needs a scope that covers the item bought (clause 3.4.4). Checking the dispatch address against the certificate is now part of goods-in.
The notification chain: who hears, and how fast
Once a gluten-free product is withdrawn or recalled, notifications follow a set pattern, some on short clocks. Elmarie put them on one page with a name against each.
| Event | Notify | Deadline | Reference |
|---|---|---|---|
| Consumer complaint mentioning symptoms | Nobody outside yet: trained staff log and investigate it | Without delay | 3.7.1 |
| Investigation confirms the product very likely fails | The certificate-issuing CB and BRCGS | On confirmation; the Standard sets no figure | 3.7.2 |
| Official recall or withdrawal notice | The national competent authority, the CB and BRCGS | BRCGS within 24 hours; no deadline stated for the authority | 3.8.1 |
| The same event | The CB, as a change of circumstances | Immediately | Part III 5.1.1 |
| Any of these on a Crossed Grain product | AOECS member society; brand owner | Society within 24 hours; both immediately on licence matters | 8.2.1, Part III 4.10 |
| The follow-up | The CB: corrective action, root cause, preventive plan | Within 21 calendar days | 3.8.1 |
| A trademarked product delisted | BRCGS; Schedule A corrected | Immediately | 6.2.1 |
The Standard puts no time limit on telling the competent authority; the law you operate under decides that, so check it rather than guessing. Rehearse the whole chain, not just the trace, in the yearly mock recall on a gluten-free product (clause 3.8.2): write the BRCGS notice for real, ring the CB number on file, and time each decision. Kwaggasdrift’s notice reached BRCGS the morning after the official notice, and its 21-day pack went to the CB on day 16. Our article on allergen recalls, rework and line clearance explains why so many recalls start on the packing line.
BRCGS Gluten-Free audit findings: critical, major and minor
The other half of claim risk is the audit. Issue 4 never gives the site an overall rating: there is no letter grade, and no shorter or longer audit interval as a reward or penalty. The auditor grades each non-conformity, CB management verifies the grading, and the mix decides what happens next:
- Critical: gluten control has broken down seriously, or the site has a legal problem.
- Major: a requirement is largely unmet, or what the auditor saw raises serious doubt about whether product being supplied conforms.
- Minor: a requirement is partly met, and nothing found puts the product itself in doubt.
Two counting rules matter commercially. A run of minors against one clause may be raised as a single major instead, and minors on one clause are never merged into one to shorten the list. Some majors exist before the audit starts: a recertification audit held late without an accepted reason is raised as a major at the next audit. And one major the Standard itself uses as an example is commercial, not technical: a Schedule A that drifted out of line with trademark use because news of a sales decision never reached the quality team.
At the closing meeting the auditor confirms the findings without predicting the outcome, and a written summary follows then or within one working day; the CB’s independent certification manager decides afterwards. The GFMS team leader or deputy must attend, and directors who can approve corrective action are expected: the 28-day plan starts in that room.
Table 1 as a business forecast
Table 1 in Part III turns the count of findings into an outcome. Below is our reading of it, applied to results a site might take from a closing meeting. Some published cells are shaded rather than numbered, so confirm edge cases with your CB.
| Findings at the closing meeting | What happens next | What to plan for |
|---|---|---|
| No major, 6 minors | Evidence within 28 calendar days; certificate; 12 months | A desk exercise with senior sign-off |
| 1 major, 4 minors | Evidence within 28 calendar days; certificate; 12 months | Senior-led root cause work on the major |
| No major, 9 minors | A revisit inside 28 calendar days, physical or remote as the CB chooses; certificate if satisfied | Another visit, with its cost and disruption |
| 1 major, 7 minors | Revisit within 28 calendar days; certificate if satisfied | As above, with the major closely examined |
| No major, 11 minors | No certificate; full re-audit by the same CB after at least 28 calendar days | Any existing certificate withdrawn; customers told at once |
| 1 major, 9 minors; or 2 majors | No certificate; full re-audit | As above |
| 1 critical | No certificate; full re-audit | As above; on section 8 sites the CB tells the AOECS member society |
The bands are narrow: two or three extra minors can turn an evidence exercise into a revisit, or a revisit into a failure. Every certificated outcome brings the same 12-month frequency, so arguing a minor down gains little if the fix must still be made. Keep a running count during the audit instead, and put facts the auditor has not seen on the table. Module 5 of our BRCGS Gluten-Free Issue 4 for Management course has a scenario game built on these calls.
The 28-day clock and the 12-month cycle
Every finding needs a correction, a root cause analysis and a preventive action plan, and all three must reach the CB within 28 calendar days of the audit, weekends included. Miss it and no certificate is issued; only a new full audit reopens the door. Longer preventive work, such as new extraction, need not be finished in 28 days, but the plan must be credible and dated. BRCGS prescribes no root cause method; asking “why?” repeatedly is the simplest, and the aim is the system gap, never a person to blame. For worked examples, see our article on corrective action and root cause analysis for audit findings. The decision and certificate follow within 42 calendar days, and the report reaches the Directory within 49 days, certificated or not. An appeal, lodged in writing within 7 calendar days of a decision, does not stop the 28-day clock.
The 12-month cycle is where avoidable majors come from. On the standalone route each re-audit falls in the 28 calendar days before the due date, counted from the first day of the initial audit; a combined audit follows the food safety scheme. The site must make sure recertification happens on time (clause 1.1.4), and an audit that slips without a justifiable reason earns a major next time. Acceptable reasons are outside the site’s hands: a government warning against travel when no local auditor is available, a statutory exclusion zone, a disaster, roads closed by weather, or a crop season that starts late. Being short-staffed, having builders in, wanting to merge two audits or running below full production are not. To align audits, bring one forward instead; the report notes the reason, and the next due date becomes 12 months after the early audit.
Themba’s idea fell into the second list: a withdrawal is not an accepted reason. The audit went ahead in its window, with the withdrawal file on the table.
When certification is at risk: the certificate, the logo and the trademarks
The CB must hear immediately about changes that could affect certification: recalls and withdrawals, legal proceedings, enforcement, serious incidents, site damage, a new owner, loss of key staff or a move. It may then confirm the certificate, ask for more detail, visit, suspend while it investigates, or withdraw (Part III 5.1.1). Other grounds for withdrawal include evidence that seriously questions product conformity, corrective action plans that run late, records that have been falsified, and contract breaches such as not paying fees (Part III 5.4). The CB or BRCGS may also visit between audits, and findings must then be closed within 28 calendar days. The marks follow the certificate, and that multiplies the damage.
| Event | BRCGS Gluten-Free logo | BRCGS-managed trademarks | Who you must tell |
|---|---|---|---|
| Suspension | Stops | Stop | Customers, at once (Part III 5.6) |
| Withdrawal | Stops | Stop until certification is regained | Customers, BRCGS, and any brand owner relying on those marks (Part III 5.4) |
| Expiry without renewal | Stops | Stop; product made before expiry may keep them | Customers, as good practice |
Crossed Grain products add a layer. The licence is held under a contract with the national AOECS member society (clause 8.5.1). A critical finding or a failed audit is reported to that society by the CB itself, at once, and anything else that could touch the licence, a recall included, goes from you to both the society and the brand owner without delay (Part III 4.7, 4.10). Section 8 is certificated only alongside full Gluten-Free certification, so losing the certificate takes it too. Misusing the logo or a mark is itself referred and can cost the certificate (Part III 5.7, 5.8), so keep a register of every pack, page and brochure carrying them, with a named person who can take them down fast.
A readiness plan for protecting the certificate
Certificates are mostly protected, or lost, between audits. This plan, run by the team leader and owned by a director, uses our suggested timings, not the Standard’s. For a first audit, our BRCGS Gluten-Free certification overview sets out the different sequence.
| When | What to do | Clauses behind it |
|---|---|---|
| Monthly | Gluten results, symptom complaints, supplier changes and open actions reported upwards | 1.4.3, 2.3.1 |
| Quarterly | Claim register: product, market, limit and source, marks, Schedule A | 4.3.1, 6.3.1 |
| Yearly | Policy re-signed; senior manager at a team meeting; internal audits; ISO 17025 verification; system review; mock recall | 1.1.1, 1.4.2, 3.3.1, 4.7.2, 2.3.1, 3.8.2 |
| Twelve weeks out | Date inside its window; meeting attendees diarised; position statements checked; in-scope production planned | 1.1.3, 1.1.4 |
| Audit days | A running count; proof last year’s preventive actions worked | Part III 3.3 |
| Day 0 to 28 | One owner per finding; pack checked by a second person; senior sign-off | Part III 3.3, 3.4 |
Five things to do this week
- Write down who may call a withdrawal or recall, who stands in at night and over weekends, and who drafts each notification.
- Open the recall procedure and confirm the CB contact is current, the BRCGS notification route is written down, and the last mock recall used a gluten-free product.
- Copy three dates into the board calendar: the audit due date, the day its 28-day window opens, and the certificate expiry.
- List every pack, page and document carrying the BRCGS logo or a gluten-free trademark, and name the person who would remove them.
- Ask your team leader for last year’s audit findings and check that each preventive action was completed and actually worked.
Related course: BRCGS Gluten-Free Issue 4 for Management
Written for the people who carry these decisions: owners, directors and senior managers at gluten-free sites. Four hours, self-paced. Module 4 covers testing, incidents, withdrawal and recall, and Module 5 covers audit options, findings against Table 1, the 28-day clock, the 12-month cycle and keeping the logo and trademarks, with case studies, knowledge checks and scenario games throughout, and a final assessment for an ASC course certificate. It 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 BRCGS Gluten-Free Issue 4 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
What is gluten-free claim risk?
It is the commercial exposure when a product sold as gluten-free does not meet its claim, through a high result, a complaint, a wrong pack or misused wording. It can lead to a withdrawal or recall, lost listings, stopped trademark use and, under BRCGS Gluten-Free Issue 4, action against the site’s certificate.
Who must be told about a gluten-free product recall under BRCGS Gluten-Free Issue 4?
Three bodies: the national competent authority, your certification body and BRCGS. BRCGS must hear no later than 24 hours after the official notice is issued, and the certification body needs corrective action, root cause analysis and a preventive action plan within 21 calendar days. Crossed Grain products add the AOECS member society within 24 hours.
How many non-conformities can a site have and still be certificated?
As we read Table 1: no major with up to 7 minors, or one major with up to 5, earns a certificate once evidence is accepted; no major with 8 to 10 minors, or one major with 6 to 8, needs a revisit within 28 calendar days; any critical, two or more majors, one major with over 8 minors, or over 10 minors means no certificate.
Can we postpone a BRCGS Gluten-Free recertification audit?
Only for a justifiable reason outside your control, such as official travel advice with no local auditor, a disaster, blocked access or a late seasonal crop. Short staffing, building work or wanting to combine audits are not enough, and a late audit without a valid reason becomes a major at the next audit. Bringing an audit forward is allowed.
What happens to our trademarks if the certificate is suspended or withdrawn?
The BRCGS Gluten-Free logo and any BRCGS-managed trademarks come off immediately. Customers must hear at once, and a withdrawal must also be reported to BRCGS and to every brand owner using those marks. If a certificate simply expires, products made before the expiry date may keep their marks, but new production may not.
Next step. If your managers need to rehearse these decisions before the next audit, the BRCGS Gluten-Free Issue 4 for Management course works through incidents, findings and the certification cycle with South African case studies and scenario games. Teams on the floor can start with the Introduction to BRCGS Gluten-Free Issue 4 course, and 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, confirm audit options and timings with your certification body, and confirm the gluten-free claim rules of every market you sell into, South Africa included. 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.