A plant-based sausage maker in Montague Gardens, Cape Town, ran short of its usual smoky seasoning during a busy December and its supplier sent a replacement blend under the same product name. The bag looked identical and the code had not changed, so goods-in booked it in. Three weeks later a retailer’s technologist, reading the new specification for an unrelated reason, found lactose listed as the carrier for the smoke flavour. Nothing was wrong with the sausages from a food safety point of view, but every pack made in those three weeks had been sold as plant-based when it was not. Plant-based cross-contamination rarely looks like a dramatic spill. It is usually a hidden animal ingredient in a carrier, a glaze, a processing aid or a shared tool that nobody thought of as an ingredient at all.
In short
- Under the BRCGS Plant-Based Standard a product is plant-based only if no material of animal origin was used on purpose at any stage, so carriers, enzymes, glazes and processing aids count even when nothing is left in the pack.
- “Animal origin” includes anything produced by an animal: milk, eggs, honey, beeswax, shellac and insect-derived colours such as cochineal.
- Many materials, including glycerol, stearates, some amino acids, vitamin D and E631, can be made from plants or animals. Only the supplier’s declared source settles it.
- The risk assessment must cover every input, not just ingredients: processing aids, packaging and cleaning materials, reviewed at least every three years and whenever something changes.
- Goods-in checks catch most hidden changes: the approved supplier list, current versions only, a documented physical check of printed labels, and batch-specific certificates from accredited laboratories where testing is needed.
- Cross-contamination controls are risk-based, not a fixed list: scheduling, people, PPE, tools, storage, rework, airflow and cleaning between runs. The Standard sets no numeric limit for traces.
- Labels are re-approved after every recipe change, the mark goes only on Schedule A products, and old packaging is quarantined.
Why hidden animal ingredients are the real risk
Most plant-based failures are not caused by someone adding cream to a vegan dessert. They come from materials that sit one or two steps away from the recipe: the carrier inside a flavouring, the enzyme in a dough improver, the glaze on a coated nut, the fining agent a supplier used before the juice reached you. That is why the Standard defines plant-based by what was used, not by what can be detected. If something of animal origin went into the product or was used to make it, deliberately, at any point in processing, the product is not plant-based, even if no laboratory could find a trace.
The second trap is the word “animal”. Under the Standard, material of animal origin is anything that comes from an animal or is produced by one. Dairy, eggs, honey and beeswax count although no animal is killed to obtain them. Insects count, which puts cochineal and carmine reds out of bounds. So do materials made from wool, feathers or hair, such as lanolin and some amino acids. If your team’s working rule is “no meat, no fish”, it will miss half the list.
The Standard supports this with Appendix 4, a grouped list of common animal-origin materials that clause 13.1 asks product developers to use, and that feeds the raw material and vulnerability assessments. Use it as a checklist of questions for suppliers rather than a list of banned names, because many entries can also be made from plants. For how certification itself works, from Schedule A to the pass-or-fail audit, see our companion guide, BRCGS Plant-Based certification explained.
Where animal-derived material hides in a plant-based factory
The table below groups the usual suspects by where they hide in your supply chain, not by chemistry. Build your own version from your recipes and suppliers, and expect it to be longer than you think.
| Where it hides | Typical examples | The question to ask the supplier |
|---|---|---|
| Colours and E-numbers | Cochineal or carmine red (E120), edible bone phosphate (E542), disodium inosinate (E631), beeswax (E901), shellac (E904). | What is the source of each additive, and will you tell us before it changes? |
| Carriers in flavourings and seasonings | Lactose, whey or milk powders used to carry a flavour, meat or fish extracts in savoury “natural flavourings”. | Give us the full breakdown, including the carrier and every component of the flavouring. |
| Enzymes | Rennet and pepsin, which come from animal stomachs, in cheese powders and cheese-flavoured seasonings. | Is the enzyme animal, microbial or plant-derived? |
| Fining and clarifying agents | Gelatine, isinglass (from fish bladders), casein or egg white used to clear juices, vinegars, wine and beer. | What was used to fine or clarify this batch, even if it was removed? |
| Glazes, coatings and release agents | Shellac and beeswax on confectionery, coated nuts and fruit; animal fats or stearates in release agents and pan oils. | Which coating or release agent touches the product, and what is it made from? |
| Fortificants and supplements | Vitamin D3, which is often made from lanolin in sheep’s wool; fish oils for omega-3; gelatine capsules in natural health products. | What is the source of the vitamin, oil or capsule shell? |
| Refining and processing | Bone charcoal used to decolour some refined sugar; animal-derived fatty acids and glycerol in processed oils and emulsifiers. | Was any animal-derived material used in refining or processing, not just in the formula? |
Notice how few of these would appear as a separate line on a finished product’s ingredient list. A carrier may be declared under the flavouring, a fining agent may not be declared at all, and a release agent is usually treated as a processing aid. That is exactly why the Standard’s definition reaches them, and why your specifications have to as well (9.1).
Inputs that are not ingredients: packaging, lubricants, cleaning and services
The Standard deliberately uses the word “input” for anything that is not an ingredient but is needed to make the product and could carry animal-origin material into it: processing aids, packaging and cleaning materials are the examples it gives. Clause 6.1 asks for a documented risk assessment of all ingredients and inputs that identifies potential animal-origin material, hidden sources included, and that assessment then drives what you accept, what you test and how you approve and monitor suppliers. It is reviewed when a material, its processing or its supplier changes, when a new risk emerges or a recall involves the material, and at least every three years.
On the floor, the inputs most often missed are the ones engineering and the cleaning crew buy. A food-grade lubricant or release agent can contain animal-derived fats or stearates. A pan oil or anti-stick spray may have a different source from the one in the recipe. Casings, films, coatings and adhesives that touch product deserve the same question. And service providers can carry animal material in on their equipment and clothing, which is why section 8 asks you to assess pest control, laundry, contract cleaning, maintenance contractors, hauliers, off-site stores, laboratories and waste collectors for plant-based risk and to write the controls into their contracts.
| Input or service | How animal material gets in | A practical control |
|---|---|---|
| Release agents, pan oils, lubricants | Animal fats, stearates or fatty acids in the formulation. | Specification with a declared source, held by engineering as well as QA. |
| Packaging, casings and coatings | Animal-derived casings, gelatine coatings, glues or waxes on surfaces that touch food. | Include packaging suppliers in the risk assessment and supplier approval. |
| Contract laundry | Plant-based overalls washed with abattoir or meat-plant clothing. | Contract clause for separate washing, checked at the laundry visit. |
| Contract cleaners and fitters | Equipment, tools or clothing brought straight from a meat or dairy site. | Clean-in rules for tools, site induction, dedicated kit for plant-based areas. |
| Hauliers and off-site storage | Open plant-based ingredients carried or stored next to open meat or dairy. | Mixed-load rules and vehicle cleaning written into the contract. |
| Pest control | Bait formulations containing animal-derived material. | Agree bait types for plant-based areas in the service contract. |
Maintenance teams are often the weak link because they move between lines, borrow tools and rarely sit in hygiene training. The Food Safety for Engineering and Maintenance Teams course covers the habits that matter, and clause 20.1 expressly includes engineers in plant-based awareness training.
Goods-in checks that keep a plant-based claim honest
Goods-in is where most hidden changes can still be stopped. The Montague Gardens seasoning would have been caught by any one of three checks the Standard expects: a supplier guarantee requiring advance notice of blend changes (6.2), a goods-in system that accepts only the approved version of each material (7.2), and a comparison of the supplier’s ingredient declaration with your own recipe records (7.4).
| Check at receipt | What the receiving clerk looks for | Clause |
|---|---|---|
| Approved supplier | The supplier and material are on the approved list and flagged for plant-based use, and the list is on hand at the receiving bay. | 6.4 |
| Correct version | The delivery matches the current approved version: same code, same pack design, no “new improved” flash. Anything different is held until QA clears it. | 7.2 |
| Declared ingredients | The ingredient declaration on the bag or drum still matches your recipe records, carrier and components included. | 7.4 |
| Certificate of analysis | Where the risk assessment calls for testing, a certificate specific to this consignment from an accredited laboratory, not a generic annual one. | 7.1 |
| Printed labels and packaging | A documented physical comparison of the delivered labels against the approved artwork, signed and kept with a retained sample. | 7.3 |
| Visual checks | Damaged packs, open liners or contamination from a mixed load. | 7.1 |
Write a short acceptance list naming each plant-based ingredient and input with its criteria and testing frequency, and keep photographs of the current approved pack at the bay. When a supplier changes a label, approved changes must reach goods-in before the delivery does. The weakest moment is the emergency purchase: the Standard requires emergency suppliers to go through the same approval, and a shortage is exactly when a cheaper protein from an unknown broker can arrive bulked with whey.
Plant-based cross-contamination controls on a shared site
The Standard expects shared sites. It does not demand dedicated lines; it asks you to control cross-contamination where it applies, based on risk, and lists the factors you must at least consider (17.1). Use the list as the structure of your risk assessment, decide which controls you need, and be able to explain why you rejected the others.
| Factor to consider | What good control looks like on the floor |
|---|---|
| Production scheduling | Where lines are shared, plant-based runs first after a full clean, with dairy or meat products later in the cycle. |
| People and material movement | A traffic plan so staff do not walk from a meat or dairy area into a plant-based area without changing and washing, and handling rules for materials at receiving, storage, processing and packing. |
| Uniforms and PPE | Dedicated or colour-coded overcoats, aprons and gloves for plant-based areas, changed at the boundary. |
| Storage | Dedicated or clearly segregated racking for plant-based ingredients, work in progress and finished goods, marked on the floor plan. |
| Bulk containers | Bins, IBCs and totes identified for plant-based use and cleaned before reuse. |
| Utensils, equipment and areas | Colour-coded scoops, paddles, scrapers and jugs, stored separately. |
| Maintenance tools | A dedicated tool set for plant-based lines, or a cleaning step before tools move across. |
| Hygienic design | Equipment and tools that can be fully cleaned, with no dead spaces where residue from a dairy or meat run can sit. |
| Cleaning during operations | A defined clean of product-contact surfaces between runs where equipment is not dedicated, with verification. |
| Airflow | Dust from milk powder or egg powder kept away from open plant-based product by extraction, distance or timing. |
| Dual-use ingredients | Ingredients used in both plant-based and other recipes kept closed, labelled and handled so they cannot pick up animal material. |
| Rework | Plant-based rework only, labelled and segregated, going back into plant-based product. |
Verification is where many sites fall short. A changeover clean that is signed off but never checked tells the auditor nothing. Visual inspection is the minimum. Where the risk justifies it, protein or ATP swabs and, for dairy or egg, specific tests give harder evidence; the Standard does not prescribe a method, so choose and justify one. The techniques overlap heavily with allergen work, and our article on allergen cleaning validation explains the difference between a documented clean and a validated one. Remember that milk and egg are both animal-derived and major allergens, but the plant-based claim covers far more than allergens: honey, gelatine and shellac are not allergens and still break the claim.
Rework, recipes and work in progress
Rework is the quietest route for animal material into a plant-based product, because it looks like your own product and moves around the factory without a supplier label. Clause 18.2 asks for rework rules that keep animal-origin material out, typically through control and labelling. In practice that means rework from a dairy or meat run never goes into a plant-based batch, plant-based rework is labelled with the product and recipe it came from, and it is stored apart and recorded so it can be traced.
- Label every container of rework with the source product, date and a clear plant-based identifier, and keep it in a marked area.
- Like into like only: plant-based rework goes back into the same or an equivalent plant-based recipe, and the batch record says so.
- Check the weighing and mixing step (18.1). Batch sheets with lot numbers ticked off, or scale and barcode checks, stop the wrong bag going into the mixer.
- Label decanted ingredients and work in progress (18.3). An unmarked tub of white powder at a shared mixing station could be pea protein or milk powder, and nobody should have to guess.
The same thinking applies to recipe changes. A new plant-based product, or any change to a recipe, packaging or processing method, needs formal sign-off by the HACCP team and the qualified individual before it enters the factory (13.2). A trial run on the line before that sign-off is a non-conformity waiting to happen, and keeping launch, purchasing and planning decisions inside that gate is a leadership job, set out in our guide to BRCGS Plant-Based management responsibilities. Our article on rework, packaging and line clearance covers the allergen side of the same controls, and most of it transfers directly.
Labels, the trademark and obsolete packaging
Labelling is where a hidden ingredient becomes a public claim. The Standard asks for a label approval process that includes re-approval whenever a formulation changes (14.1), and for finished-product labels that accurately reflect the product’s name and composition (14.2). Where a retailer or other customer controls the artwork, you must give them the information they need and tell them whenever something changes, because their label will only be as accurate as your notification.
The plant-based trademark carries its own rules. It may appear only on products listed on your current, BRCGS-approved Schedule A, and every use of the mark or the Standard’s name, on pack, online or in advertising, needs BRCGS approval, must follow the trademark usage guide and must comply with the law of the market where the product is sold (16.1). Labelling law differs between markets, so check the rules for each market you sell into. In South Africa the use of meat-style names on plant-based products has been contested: in 2024 the High Court in Johannesburg set aside a government directive and planned seizure aimed at meat analogue products sold under names such as “nugget” and “sausage”. Take current legal advice for your own labels rather than relying on news reports.
Old packaging is the last trap. When a recipe changes and the product loses its plant-based status, or the artwork moves to a new version of the mark, the superseded packaging must be segregated and disposed of so it cannot be used by mistake (19.1). The Standard treats labels as any pre-printed packaging carrying an ingredient list, and includes obsolete ingredients, work in progress and finished goods. A quarantine cage, a destruction record and a quick check of the packaging store before every audit will save you a finding. For a tight sign-off routine, our food label sign-off checklist is a good base.
When a recipe change breaks the claim
A granola bar gains honey in a new recipe. The specification is updated, but nobody tells the packaging buyer, and the old film with the plant-based mark is still on the line the next morning. Three clauses stop this: re-approval of labels after a formulation change (14.1), control of obsolete packaging (19.1), and an update to Schedule A so the product either comes off the list or the recipe is rejected. Put all three on one change-control form.
Training the people who make the claim real
Every control above depends on someone on the floor knowing why it matters. Clause 20.1 requires plant-based awareness training in the site’s training programme for all relevant personnel, explicitly including engineers and maintenance staff, temporary workers and contractors, at a frequency set in advance and at least once a year. Where relevant it should cover the ingredients, components and processing aids that contain animal-origin material, how people, equipment and waste move around the site, dedicated areas, equipment and tools, segregation, dedicated uniforms and PPE, job rotation, and the management of contractors, visitors and temporary workers.
Agency staff are the obvious gap on South African sites with seasonal peaks. If a temporary worker rotates from the dairy hall to the plant-based hall without changing their overcoat, the procedure has failed, not the worker. Short toolbox talks at the boundary, colour-coded PPE that makes a mistake visible, and a sign-off before the first shift do more than a long induction. The Introduction to BRCGS Plant-Based Issue 1 course can form part of that awareness training alongside your own site-specific briefing.
Five things to do this week
- Pick your five highest-volume plant-based products and list every flavouring, seasoning, enzyme, colour and coating in them. For each, check the specification states the source of the carrier and every component.
- Ask engineering for the specifications of every lubricant, release agent and pan oil used on plant-based lines, and add them to the raw material risk assessment.
- Stand at goods-in for one delivery and watch. Is the approved supplier list there, is there a photo of the current pack, and would the clerk notice a new version?
- Walk one changeover from a dairy or meat run to a plant-based run and note every shared tool, glove, bin and surface. Each one needs a control or a reason why not.
- Open the packaging store and look for any film or carton carrying the plant-based mark for a product that is no longer on Schedule A. Quarantine it today.
Related course: Introduction to BRCGS Plant-Based Issue 1
Five hours, self-paced, in three modules and twelve lessons: where animal-derived material hides, the goods-in, cross-contamination, rework and labelling controls covered here, all 20 sections of the Standard, and the certification audit. It is independent awareness training that can support your clause 20.1 training, and it 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 counts as an animal-derived ingredient under the BRCGS Plant-Based Standard?
Anything that comes from an animal or is produced by one, used on purpose at any stage of production. That includes meat, fish, dairy and eggs, but also honey, beeswax, shellac, gelatine, insect-derived colours such as cochineal, and materials made from wool, feathers or hair, such as lanolin-derived vitamin D3. Appendix 4 of the Standard lists common examples.
Do processing aids and carriers count if nothing is left in the product?
Yes. The definition covers any material of animal origin used intentionally to make the product, including carriers, enzymes, flavourings and processing aids, even when nothing measurable remains. A juice fined with gelatine or a seasoning on a lactose carrier is not plant-based under the Standard.
Is there a limit for animal-derived traces in a plant-based product?
No. The Standard sets no numeric limit or detection threshold. Unintentional cross-contact is managed through risk-based controls: the HACCP plan, supplier approval, goods-in checks and the cross-contamination procedures in clause 17.1. Agree your testing approach and any “may contain” wording with your certification body.
Do we need dedicated lines to make plant-based products?
No. The Standard expects shared sites and asks you to consider, based on risk, controls such as scheduling plant-based runs first, people movement, dedicated PPE and tools, segregated storage, rework rules, airflow and cleaning between runs. You must be able to show why the controls you chose are enough.
How often must the raw material risk assessment be reviewed?
At least every three years, and sooner whenever an ingredient or input, its processing or its supplier changes, a new contamination risk emerges, or a recall or withdrawal involves the material. It must cover inputs such as processing aids, packaging and cleaning materials, not only ingredients.
Can rework be used in plant-based products?
Yes, with control. Rework must not bring animal-origin material into a plant-based product, so in practice only plant-based rework goes back into plant-based recipes, labelled with its source, stored apart and recorded so it can be traced.
Next step. To give goods-in, production, engineering and QA the same picture of where animal-derived material hides, the Introduction to BRCGS Plant-Based Issue 1 course works through every section of the Standard with South African examples and a knowledge test after each module. 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.