Kransvlei Foods, a frozen dessert maker in Pietermaritzburg, had sold its oat-based ice creams under the BRCGS plant-based mark for eight months when a customer with a milk allergy reacted to a tub of the chocolate flavour. The laboratory found casein. A cocoa blend bought from an unapproved broker during a shortage had been bulked with milk powder. The company issued a withdrawal the next morning, and only then noticed that its recall plan did not name the certification body, which had to be told within 24 hours of the official notice. The call was made with hours to spare. The retailer asked for a root cause report before it would take another order, marketing pulled a winter campaign built around the mark, and the stock sat in quarantine while the investigation ran. Plant-based claim risk is the cost of the claim failing in the market, not the cost of an audit, and managers planning certification should price it before they book one.
In short
- A failed plant-based claim costs far more than certification: withdrawn stock, investigation time, retailer scrutiny, pulled marketing and, at worst, a suspended or withdrawn certificate.
- If a plant-based product is recalled or withdrawn because of animal-origin contamination, the certification body must be told within 24 hours of the official notice (12.1), and the system and risk assessment are reviewed (3.1, 6.1).
- On suspension or withdrawal every use of the plant-based mark stops, and BRCGS may tell the brand owner. Some customers also require immediate notice of serious audit findings or a failed certification.
- A documented vulnerability assessment of all plant-based ingredients and inputs for substitution with animal-origin material is formally reviewed every year (15.2), with testing or assurance for high-risk materials (15.3).
- The route runs from Schedule A through preparation to an audit of about one day (roughly half a day more when combined), then 28 calendar days to close every non-conformity with evidence. There are no grades: certified or not.
- The report and certificate follow within 42 calendar days of the last audit day, and re-audits fall every 12 months inside a 28-day window ending on the due date.
Plant-based claim risk: where a claim usually fails
Shoppers cannot spot animal-derived ingredients from a label, so they rely on the mark, and the mark is only as good as the controls behind it. For a manager that makes the claim a business risk with a handful of usual causes, each with a control in the Standard and an early warning sign leaders can watch.
| Risk | How it usually arises | Control in the Standard | Early warning for managers |
|---|---|---|---|
| Animal-origin material arrives from a supplier | A blend is reformulated without notice, or an emergency supplier is used without approval. | Supplier approval, guarantees, specifications and goods-in checks (6.2, 7.2, 7.4, 9.1) | Emergency purchases, new suppliers and specification changes in the month |
| Deliberate substitution in the supply chain | Price spikes or shortages make cheaper animal protein attractive to someone upstream. | Horizon scanning, vulnerability assessment and testing (15.1 to 15.3) | Price movements, supply alerts and brokers appearing on purchase orders |
| Cross-contact on a shared site | Cleans between runs are squeezed, tools are shared, rework is mixed. | Risk-based cross-contamination and rework controls (17.1, 18.2) | Changeover overruns and failed clean verifications |
| The mark used where it should not be | A recipe changes, or marketing features a product not on Schedule A. | Label approval, marketing claims and obsolete packaging (14.1, 16.1, 19.1) | Artwork changes and campaigns that do not pass through the qualified individual |
| The certificate lapses | The food safety certificate, Schedule A or BRCGS fees lapse, or the re-audit window is missed. | Preconditions for certification (1.2, Part III) | Renewal dates held by one person and nowhere else |
Who owns each of these decisions, from budgets and schedules to supplier and marketing sign-off, is covered in our companion guide to BRCGS Plant-Based management responsibilities, and the floor-level checks behind the first and third rows in our guide to hidden animal ingredients and plant-based cross-contamination.
What a failed plant-based claim costs the business
Most of the cost of a failed claim never appears on an audit invoice. It sits in stock, staff time, customer goodwill and marketing that has to be undone. The table separates what the Standard sets from what usually follows commercially.
| Consequence | Set by the Standard | What it usually means commercially |
|---|---|---|
| Recall or withdrawal of plant-based product | The certification body must be told within 24 hours of the official notice where animal-origin contamination is the cause (12.1). | Stock in quarantine or destroyed, retrieval costs, and senior people pulled into the investigation for days. |
| Investigation and review | Complaints are recorded and substantiated ones investigated to root cause (11.1); the PBMS and the raw material risk assessment are reviewed after a recall (3.1, 6.1). | Technical time diverted from development and audits, and possibly new testing, suppliers or equipment. |
| Suspension of certification | Possible where the site does not comply, or BRCGS and the certification body believe continued certification would endanger public health or damage BRCGS’s reputation or the plant-based status of products. It lasts until corrective measures are verified. | No use of the mark while it lasts, which can halt labelled production. |
| Withdrawal of certification | Possible where corrective measures are not completed in time, false or misleading information is supplied, or the site leaves the programme. A certified site whose audit rules out certification loses it immediately. | The mark comes off every pack until certification is regained. |
| Loss of the mark | All use of related logos and trademarks stops on suspension or withdrawal, and BRCGS may tell the brand owner. | Packaging and campaigns carrying the mark become obsolete overnight. |
| Customer notice | Where a customer requires it, it must be told immediately of serious audit findings or a failed certification, with full details. | Retailer reviews, improvement plans and pressure on future orders and listings. |
Customers do not have to wait to be told: certificate validity can be checked on the BRCGS Directory, and where agreements exist BRCGS may share reports and certificates with customers unless the site switches sharing off.
Marketing carries a cost of its own. Superseded packaging carrying the mark is controlled as obsolete material (19.1), so a suspension or a recipe change can turn printed film, a retailer promotion and a season of social media content into write-offs. Keep a register of where the mark appears, so you know what has to be pulled and how fast.
The 24-hour call: recall and withdrawal under the Standard
Clause 12.1 is short and unforgiving. When animal-origin contamination is the reason a plant-based product is recalled or withdrawn, the certification body that issued your current plant-based certificate has to hear from you within 24 hours of the official notice being issued. The clock starts with the notice, not when the investigation ends, so the call is made before all the facts are in.
Three decisions make that call possible: name the certification body contact in the recall plan, with a deputy; decide in advance who authorises the notification, because waiting for a travelling director is how a 24-hour deadline is missed; and rehearse it: run the yearly traceability test on a plant-based product in both directions with a mass balance, as clause 10.1 requires, and use the same exercise to practise the notification step.
After the call comes follow-through: substantiated complaints investigated to root cause, with action in proportion to how serious and frequent the problem is (11.1), and a review of the PBMS (3.1) and the raw material risk assessment (6.1). A board that closes the withdrawal once the stock is back has done half the work.
The vulnerability assessment: pricing the fraud risk
Accidental cross-contact is only one way a claim fails. The other is deliberate: someone upstream substitutes or bulks a plant-based ingredient with cheaper animal-derived material for profit. Clause 15.1 asks for ways to gather information on past and emerging supply chain threats, such as trade associations, government sources and private resource centres. Clause 15.2 asks for a documented vulnerability assessment of all plant-based ingredients and inputs, or groups of them, for the risk of adulteration or substitution with animal-origin material, turned into a documented plan. Clause 15.3 asks for assurance or testing where a material is found to be at particular risk.
Read the factors the Standard names as questions for a buyer and a technical manager to answer together.
| Factor to consider (15.2) | The management question |
|---|---|
| Past evidence of substitution or adulteration | Has this material, or anything like it, been adulterated before, here or elsewhere? |
| Economic factors that make fraud more attractive | Has the price risen sharply, or is supply short, so that a cheaper substitute pays? |
| How easily the material can be reached in the supply chain | How many hands and stores does it pass through, and do we know them all? |
| How sophisticated routine testing for adulterants is | Would our usual checks and the supplier’s certificate actually catch an animal protein? |
| The nature of the material | Is it a powder, a blend or a concentrate in which something could be hidden? |
The assessment stays under review as prices and market intelligence change, and is formally reviewed every year. Link it to purchasing: a shortage, a price spike or a new broker should trigger a look straight away. The method itself, from scoring to a worked example, is set out in our guide on how to do a food fraud vulnerability assessment.
Decisions to make before you book a plant-based certification audit
The process itself, from Schedule A to audit day, is set out in our explainer on BRCGS Plant-Based certification. For a manager the useful question is which choices made now decide whether the audit can succeed, and when. Five shape the whole plan.
- Which products go on Schedule A. Only listed products may carry the mark, and Schedule A must be approved by BRCGS and be less than a year old. The Standard has no separate scope-extension procedure, so ask your certification body how products are added later.
- Standalone or combined. A standalone audit is open only to sites already certified to a GFSI-benchmarked scheme or BRCGS START! at intermediate level. A combined audit runs alongside the food safety audit, and when that is a GFSI-benchmarked scheme the re-audit dates follow its protocol. If you have no food safety certificate yet, combined is the only route, and failing the food safety side means no plant-based certificate either.
- Which certification body. BRCGS publishes approved bodies with a performance star rating on the BRCGS Directory but recommends none. Some customers accept only 4- or 5-star bodies, so ask your key customers before you ask for quotes.
- When plant-based product will be running. The audit must be booked for a time when plant-based production is under way. The walk-through alternative exists only within an unannounced combined audit and is not allowed for a first plant-based audit, so check the production calendar before agreeing a date.
- Who owns the project. The qualified individual leads the technical work, but someone with budget authority has to own the dates, the resources and the decisions in this article.
A realistic readiness timeline, from Schedule A to certificate
The Standard sets only one readiness figure: a new or newly commissioned site is unlikely to demonstrate full compliance less than three months after it starts operating. For an established site the limit is evidence rather than paperwork. Several activities run on a yearly cycle, so plan for each to have been completed at least once before the audit: the PBMS review, internal audit of every PBMS activity, the traceability test on a plant-based product, the vulnerability assessment review and awareness training. The phases below are our suggestion for a site that already holds a GFSI-benchmarked certificate, not timescales from the Standard.
| Phase | What gets done | Gate before moving on | Owner |
|---|---|---|---|
| 1. Decide | Schedule A product list drafted, route chosen (standalone or combined), customers asked which certification bodies they accept, budget approved. | Signed scope and budget; Schedule A ready to submit. | Managing director with the qualified individual |
| 2. Appoint and train | Qualified individual confirmed against the definition and booked on BRCGS’s site training course; HACCP team briefed; awareness training planned for all relevant staff, contractors and agency workers included. | Qualified individual in post, with written authority. | Site manager and HR |
| 3. Build | HACCP plan extended to animal-origin contamination; risk assessment of every ingredient and input; supplier files rebuilt by one of the two routes; vulnerability assessment and plan; cross-contamination, rework, label and obsolete-packaging controls. | Every plant-based supplier approved; floor controls in use. | Qualified individual with purchasing and production |
| 4. Run and evidence | Internal audit of every PBMS activity, traceability test on a plant-based product with a mass balance, PBMS review, training delivered, a preliminary self-assessment with gaps closed. | Each yearly activity completed at least once, with records. | Qualified individual; senior management for the review |
| 5. Book and audit | Schedule A approved, certification body contracted, date agreed for a period when plant-based product is running, team and decision-makers available on the day and for the four weeks after. | Audit held; draft non-conformities received. | Site manager |
| 6. Close and certify | Corrective action, root cause and preventive action for every non-conformity; evidence submitted within 28 calendar days; BRCGS fees paid. | Certification decision; report and certificate within 42 calendar days of the last audit day. | Qualified individual, with budget from management |
Audit day: who and what has to be there
The audit itself is short compared with the work before it: about one day on site for a standalone audit, or roughly half a day added to a combined food safety audit, estimated in advance by the certification body from the information you give it. A manager needs two things in place. The first is production, because the auditor spends much of the day on the floor, watching changeovers and talking to the people who keep the records. The second is people: the qualified individual and the managers who can answer for purchasing, production and marketing decisions should be on site, and someone with budget authority should hear every non-conformity at the closing meeting, because the next four weeks depend on it. The BRCGS Plant-Based Issue 1 for Management course rehearses those four weeks with a worked first-audit case study.
The pass-or-fail decision and the 28-day evidence window
There are no grades to aim for. The Plant-Based Standard defines no critical, major or minor categories and no fundamental clauses; the outcome is certified or not certified. That makes the four weeks after the audit the real decision point. Every non-conformity needs a correction, a root cause analysis and preventive action in a dated plan sent to the certification body, closed with objective evidence such as revised procedures, records, photographs or invoices, or through a further visit.
| After the audit | Timescale | Management decision |
|---|---|---|
| Draft non-conformities left with the site at the closing meeting | Day of audit | Assign an owner and a budget to each one before the auditor leaves. |
| Corrective action evidence to the certification body | Within 28 calendar days of the audit | Approve spending on fixes that cannot wait for the next budget cycle. |
| Certification body review of the evidence | Within 14 days | Keep the qualified individual free to answer follow-up questions. |
| Audit report and certificate | Within 42 calendar days of the last audit day | Make sure every BRCGS fee is paid; neither report nor certificate is valid until it is. |
| Re-audit after an audit that rules out certification | No sooner than 28 days after the audit | Decide what must be fixed before the re-audit, and when to book it. |
Two outcomes deserve a place on the board’s risk register. If satisfactory evidence has not reached the certification body within 28 calendar days, certification is not granted and another full audit may be needed. If the number or seriousness of findings rules out certification, a new site faces another full audit, and an already-certified site has its certificate withdrawn immediately. The decision is made by the certification body’s technical reviewer after reviewing the report and your evidence, not by the auditor on the day.
The 12-month cycle: keeping the certificate
Plant-based audits are repeated every 12 months. The next audit is due 12 months after the initial audit and must take place within a 28-day window ending on the due date, which leaves time to close findings without a gap in certification. Where the audit is combined with a GFSI-benchmarked scheme’s audit, the re-audit date follows that scheme’s protocol instead. The certificate itself shows a re-audit window and an expiry date; confirm with your certification body exactly how both are worked out for your site, and book the next audit well before the window opens.
Between audits the yearly activities keep running, and so do the preconditions: the food safety certificate, BRCGS fees and a Schedule A that stays approved and less than a year old. BRCGS may also make its own visits, announced or unannounced, and sites must allow witnessed audits, so readiness has to be a habit rather than a project that ends at the certificate.
Five things to do this week
- Open the recall plan and add the certification body contact, a deputy, and the name of the person who authorises the 24-hour notification.
- List every place the plant-based mark appears or is planned to appear, on pack, in campaigns and online, and estimate what would be written off if certification were suspended tomorrow.
- Ask purchasing for the ten plant-based materials whose prices moved most this year, and check each one in the vulnerability assessment.
- Ask your two largest customers which certification bodies they accept and whether their contracts require immediate notice of serious audit findings.
- Put the readiness phases on a dated plan with an owner for each gate, and pencil in an audit window when plant-based product will be running.
Related course: BRCGS Plant-Based Issue 1 for Management
A four-hour, self-paced course for directors, owners and managers who control money, time and priorities on a plant-based site. Five modules and 35 lessons, with case studies, knowledge checks and scenario games, cover recalls and the 24-hour call, fraud vulnerability, the audit options, the 28-day evidence window and keeping the certificate year after year. It is independent ASC training and does not replace BRCGS’s own site training course for the qualified individual.
See the BRCGS Plant-Based Issue 1 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 happens if a plant-based product is recalled because of animal-origin contamination?
The certification body that issued your current plant-based certificate must hear from you within 24 hours of the official recall or withdrawal notice being issued (clause 12.1). Substantiated complaints behind it are investigated to root cause (11.1), and the plant-based management system and raw material risk assessment are reviewed (3.1, 6.1). Where public health or plant-based status is at risk, certification can also be suspended.
Can a plant-based certificate be suspended or withdrawn?
Yes. Suspension can follow non-compliance with the Standard or the law, a risk to public health or to the plant-based status of products, unpaid BRCGS fees, or insolvency. Withdrawal can follow corrective measures not completed in time, false or misleading information, or leaving the programme. In both cases all use of the mark must stop.
What is a vulnerability assessment in the Plant-Based Standard?
A documented assessment of all plant-based ingredients and inputs, or groups of them, for the risk of adulteration or substitution with animal-origin material (clause 15.2). It considers past fraud, economic drivers, access in the supply chain, how good routine testing is and the nature of each material, produces a plan, and is formally reviewed every year.
How long does a BRCGS Plant-Based audit take?
A standalone audit typically takes about one day on site, and a combined audit adds roughly half a day to the food safety audit. The certification body estimates the duration in advance from the information you give it about your products and processes.
How long do we have to close non-conformities after a plant-based audit?
Corrective action evidence must reach the certification body within 28 calendar days of the audit, and no certificate is issued until every non-conformity is addressed. If satisfactory evidence is not sent in time, certification is not granted and another full audit may be needed.
How often is a BRCGS Plant-Based audit repeated?
Every 12 months. The re-audit is due 12 months after the initial audit and must take place within a 28-day window ending on the due date. Where the plant-based audit is combined with a GFSI-benchmarked food safety audit, the re-audit date follows that scheme’s protocol.
Next step. If you are planning certification, the BRCGS Plant-Based Issue 1 for Management course covers the risk, the audit and the 28-day window with South African case studies, and the Introduction to BRCGS Plant-Based Issue 1 course gives goods-in, production and QA the shared picture the controls depend on. 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 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.