Sondela Plant Foods in Wellington makes plant-based burgers and sausages on a site that also forms beef burgers for a butchery chain, and has carried the BRCGS plant-based mark for a year. At one board meeting the directors approved three sensible-looking decisions: a cheaper pea protein from a new importer to protect margin, a second shift on the shared forming line to cover a retailer promotion, and a social media campaign for a new plant-based mince. None went through the plant-based management system: the importer never received a supplier questionnaire, the clean between beef and plant-based runs was cut to fit the extra shift, and the campaign showed the mark on a mince not yet on Schedule A. The technical manager heard about all three from the auditor. BRCGS plant-based management responsibilities sit with the people who set budgets, schedules and priorities, and the Standard expects them to build the claim into each of those decisions and to be able to show that they did.
In short
- The Plant-Based Global Standard, Issue 1, treats the integrity of a plant-based claim as a cross-functional management responsibility, not only a technical one.
- Clause 1.3 asks senior management to show the plant-based management system (PBMS) inside the site’s policy, organisation structure, management review and resource planning, with a qualified individual appointed to oversee it.
- Leadership also keeps the preconditions alive: a GFSI-benchmarked food safety certificate or BRCGS START! at intermediate level, a BRCGS-approved Schedule A under a year old, and BRCGS fees paid.
- The PBMS is reviewed at least once a year and before any change that could affect the claim, including new suppliers, recipes, equipment and production volumes (3.1).
- Every PBMS activity is internally audited at least once a year (5.1), and plant-based awareness training reaches engineers, temporary staff and contractors at least once a year (20.1).
- Suppliers, emergency suppliers included, are approved by one of two routes, and a co-manufacturer must hold its own Plant-Based certificate, with no alternative (6.2, 6.5).
- New products and changes are signed off by the HACCP team and the qualified individual before they reach the factory, and every use of the mark in marketing needs BRCGS approval (13.2, 16.1).
Why BRCGS Plant-Based management responsibilities sit with the leadership team
Part I of the Standard says what many technical managers have tried to tell their boards: protecting a plant-based claim is not a laboratory job. It names the functions that can make or break it, from development, production and engineering to procurement, distribution, marketing and HR, says the system starts with a senior management policy that steers all of that work, and gives clear evidence of leadership commitment a high priority.
The reason is practical. A shopper cannot see a lactose carrier in a flavouring or shellac in a glaze, so they rely on the mark, and the mark relies on decisions taken well away from the line: which supplier the buyer accepts in a shortage, how much cleaning time the planner leaves between runs, which product marketing features next month. The technical team writes the procedures. Only management can make the rest of the business follow them when money or time is short.
For the mechanics of certification, from Schedule A to the pass-or-fail audit, see our explainer, BRCGS Plant-Based certification explained. This article covers the leadership side.
What senior management must be able to show under clause 1.3
Clause 1.3 does not ask for a separate plant-based bureaucracy. It asks senior management to prove its commitment by making the site’s existing food safety or quality system carry the PBMS. Read the list as evidence the auditor will ask leadership to produce, not paperwork for QA to assemble the week before.
| What management must show | What the auditor looks for | Usual owner |
|---|---|---|
| A policy that covers plant-based production | A signed policy or commitment letter stating that the site makes plant-based products to the Standard, and managers who know what it commits them to. | Managing director or owner |
| PBMS duties in the organisation structure | An organogram and job descriptions giving named people plant-based duties in procurement, production, engineering, marketing and HR, not only in QA. | Managing director with department heads |
| A qualified individual appointed to oversee the PBMS | A named person who meets the definition, with written authority to stop a supplier, a launch or a production run. | Managing director or site manager |
| Management review that covers the PBMS | Minutes with plant-based agenda items, decisions and dated actions, rather than one line saying the PBMS was discussed. | Senior management team |
| Resource policies that make room for the PBMS | Budgets, staffing and production plans that visibly fund training, testing, segregation and cleaning time. | Finance director and site manager |
| The preconditions for certification | A current copy of the Standard (1.1), a BRCGS-approved Schedule A under a year old (1.2), a valid food safety certificate and BRCGS fees paid. | Site manager with the qualified individual |
The last row is easy to forget until it fails. Plant-based certification rests on the site’s GFSI-benchmarked food safety certificate or BRCGS START! at intermediate level, so a lapse there puts the plant-based certificate at risk too. Unpaid BRCGS fees lead to suspension until they are settled, and neither certificate nor report is valid until every fee is paid. Schedule A must be renewed and kept in step with what is actually made and labelled.
Certification also brings obligations only senior management can honour. The contract with the certification body commits the site to accept witnessed audits and BRCGS’s own visits, announced or unannounced, and to let audit reports go to BRCGS. False or misleading information is a ground for withdrawing certification, and where a customer requires notice of serious audit findings or a failed certification, the Standard expects you to tell them immediately and in full. The BRCGS Plant-Based Issue 1 for Management course works through each of these duties with case studies from fictional South African sites.
The qualified individual and the HACCP team
The qualified individual is the one role the Standard defines precisely: in-depth knowledge of Codex HACCP principles or an equivalent, a pass on BRCGS’s own Plant-Based Global Standard site training course, and membership of the site’s HACCP team. Senior management appoints them under clause 1.3, and the rest of the Standard leans on their judgement. They, or someone they designate, review and verify the supplier questionnaires on animal-origin control (6.2), and together with the HACCP team they formally approve every new plant-based product and every change of recipe, packaging or process before it enters the factory (13.2).
That makes the appointment a leadership decision with three parts. The first is authority: a qualified individual who cannot stop a cheaper supplier, a rushed launch or a run on an uncleaned line is a name on an organogram, not a control, so write the authority into the job description and tell every manager. The second is time: the role adds supplier reviews, change approvals and audit follow-up to someone who usually already runs QA, so take something else off that desk. The third is continuity: if the only person who meets the definition leaves, nobody can give the approvals the Standard requires, so consider training a second HACCP team member on the BRCGS course.
The HACCP team has its own plant-based job. Clause 2.1 asks for the food safety plan to include an assessment of plant-based products and the chance of contamination with animal-origin material, so in practice the hazard analysis should name that hazard wherever it can arise, such as intake, storage, shared lines, rework and packing, with a control against each. If the team needs a stronger HACCP grounding before it takes that on, fund it now rather than after the audit.
Resources: the budget lines that keep the claim honest
An auditor tests the resource commitment in clause 1.3 by following money and time. If the agreed clean between a beef run and a plant-based run takes longer than the gap in the production plan, the plan wins and the cleaning procedure becomes fiction. These decisions usually sit with a director.
| Resource decision | Clauses it supports | What breaks when it is cut |
|---|---|---|
| Time in the production plan to clean between runs on equipment that is not dedicated | 17.1 | Cleans are shortened or signed off without being done, and residue from a meat or dairy run reaches plant-based product. |
| Dedicated or colour-coded tools, utensils, PPE and storage | 17.1 | Shared scoops, overcoats and racking carry material across, and nobody can show what belongs where. |
| A testing budget for high-risk materials | 7.1, 15.3 | Consignment-specific certificates from accredited laboratories, and the testing the vulnerability assessment calls for, quietly stop. |
| Plant-based awareness training for all relevant staff, including engineers, temporary staff and contractors | 20.1 | Agency workers and fitters move between areas without knowing the rules, a common route for mistakes. |
| The qualified individual’s time, and a trained deputy | 1.3, 6.2, 13.2 | Approvals queue up, get skipped or get signed without a real review. |
| Supplier approval work, emergency suppliers included | 6.1, 6.2 | Buyers accept unapproved material during shortages because approval feels slower than the order. |
| Reviews of the raw material risk assessment and specifications | 6.1, 9.3 | Reviews drift past the three-year limit and a supplier’s reformulation goes unnoticed. |
These are small, recurring costs spread across budgets owned by different managers, which is exactly why they get cut. The PBMS only works if someone at the top treats them as one line that protects the claim.
Change control and the annual PBMS review
Clause 3.1 is where most leadership decisions meet the Standard. The PBMS has to be reviewed at least once a year and, more importantly, before any change that could affect the integrity of a plant-based product or claim. Its list of triggers reads like an operations meeting agenda: new ingredients, inputs, suppliers or recipes; new equipment or process flow; packaging, storage or distribution changes; emerging risks, such as a similar product recalled elsewhere; your own recall or withdrawal; new scientific or regulatory information; complaints and findings from your own checks or regulators; and volume changes that alter product flow, cleaning or training.
The word that matters is before. A review written after the new supplier has delivered, or the second shift has started, records a risk already taken. The practical fix is one question on every change request that reaches a director: has the qualified individual assessed the plant-based impact? Whatever the review concludes then has to reach the PBMS and the training of the people affected, in writing, with a record that it was validated.
A plant-based agenda for the annual review and your regular management review might cover the following (our suggestion, not the Standard’s wording).
- Schedule A: products added, removed or changed, and the date of BRCGS approval.
- Every change made in the year, and whether each one was assessed before it happened.
- Supplier performance on plant-based criteria, emergency purchases, and the certificate dates of any co-manufacturer.
- Complaints that suggest animal-origin content, their root causes and the trend.
- Internal audit findings on PBMS activities, and whether the actions closed.
- The yearly traceability test on a plant-based product, the vulnerability assessment review and training coverage.
- Resource requests from the qualified individual, with a decision recorded against each one.
Internal audit: how leaders find out before the auditor does
Clause 5.1 brings the PBMS into the site’s scheduled internal audit programme. How often each activity is audited depends on its risk and on how it has performed, but every activity has to be audited at least once a year. For leaders it is the cheapest early warning they have, because it checks the claim across departments rather than inside one.
Three habits make it work. Ask to see the plant-based findings, not a count, and which of them touch decisions you made. Make sure areas outside QA are audited: purchasing’s emergency suppliers, marketing’s use of the mark, engineering’s tools on shared lines and HR’s training records for agency staff. And treat an overdue action as a management failure, not a QA backlog, because a finding left open is one the certification auditor can find again. If your internal auditors need sharper technique, the Internal and Supplier Auditing Practices course covers planning a risk-based programme and auditing suppliers.
Suppliers and co-manufacturers: approvals that carry a director’s name
Procurement is where commercial pressure meets the claim most often. Clause 6.1 asks for a documented risk assessment of every ingredient and input, hidden animal-origin sources included, that drives what is accepted, what is tested and how suppliers are approved. Clause 6.2 says every supplier of ingredients or inputs, emergency suppliers included, is approved by one of two routes, and clause 6.5 gives a co-manufacturer no alternative to holding its own Plant-Based certificate.
| Decision | What the Standard expects | The question to ask before you sign |
|---|---|---|
| Approving a new ingredient supplier | Either a valid Plant-Based certificate with the material on the supplier’s Schedule A, or all three of a questionnaire verified by the qualified individual or a designate, an agreed specification and a written guarantee that the blend will not change without your prior approval (6.2). | Which route is this supplier on, and is every part of it in the file? |
| Buying from an emergency supplier during a shortage | The same approval as any other supplier. There is no shortcut for urgency (6.2). | Would we rather miss an order or risk the claim on unapproved material? |
| Outsourcing a plant-based product to a co-packer | A valid Plant-Based certificate held by the co-manufacturer, with the product on its current Schedule A. No questionnaire route exists (6.5). | Have we checked its certificate on the BRCGS Directory and seen our product on its Schedule A? |
| Contracting laundry, cleaning, haulage, pest control, storage, laboratories or waste collection | Service providers assessed for plant-based risk, such as cross-contamination, and the controls written into the contract (8.1, 8.2). | Does the contract say how this provider keeps animal-origin material away from our product? |
| Renewing a supplier contract | Performance review that includes whether the supplier keeps delivering conforming material (6.3). | Has this supplier ever sent us something that did not meet the plant-based specification? |
The co-manufacturer rule is easy to miss. A co-packer with an FSSC 22000 or BRCGS Food Safety certificate is not enough, however good its hygiene, so check the plant-based certificate before the quote is accepted, not after the first production run. The day-to-day checks that sit underneath these approvals, from goods-in and current-version controls to batch-specific certificates of analysis, are covered in our guide to hidden animal ingredients and plant-based cross-contamination.
New products, labels and marketing claims you sign off
A launch is where deadline pressure meets the claim head on. Section 13 asks for development guidelines that restrict animal-origin materials, with reference to the Standard’s list of common animal-derived materials in Appendix 4, and for every new plant-based product and every change of formulation, packaging or processing method to be formally approved by the HACCP team and the qualified individual before it enters the factory (13.2). A retailer’s launch date does not move that gate, so plan for it from day one.
Labels follow the same logic: re-approval after any formulation change (14.1), accurate names and composition, and, where a retailer controls its own-label artwork, the information it needs and notice of every change (14.2). Only products on the current, BRCGS-approved Schedule A may carry the mark, so adding a product to the range is also a Schedule A decision.
Marketing is where leadership most often loses control. Clause 16.1 says any reference to the Standard or its trademark, on pack, in advertising or online, must be approved by BRCGS, follow the plant-based trademark usage guide and comply with the law of the country where the product is sold. If you use the certificate to support a different animal-free or meat-free claim, clause 16.2 asks for a written definition of that claim, a contract with any outside mark owner and approval for each product that carries it. Put one rule in writing: nothing showing the mark leaves the building, physically or online, without the qualified individual’s sign-off and evidence of BRCGS approval.
The decisions that make or break a plant-based claim
The Sondela board did not set out to break anything. Each decision was reasonable on its own terms and failed because nobody asked the plant-based question when it was taken. These are the decisions that most often go wrong under pressure.
| Decision under pressure | How it goes wrong | The decision that protects the claim |
|---|---|---|
| Budget: cutting testing or training to protect margin | Consignment tests on high-risk materials stop and annual awareness training slips past twelve months. | Protect the plant-based lines in the budget, and require a written PBMS impact note for any cut that touches them. |
| Schedule: adding a shift or a run on a shared line | The clean between a meat or dairy run and a plant-based run shrinks to fit the plan. | Fix the agreed clean time in the planning system and find capacity elsewhere. |
| Staffing: bringing in agency workers for a peak | Untrained temporary staff move between areas in the same overcoats. | Make plant-based induction part of the agency booking, before the first shift. |
| Procurement: a shortage or a better price | Unapproved material arrives from a broker and goes straight into production. | Hold the order until approval is complete, or keep pre-approved backup suppliers. |
| Launch: a retailer brings the date forward | A trial runs before the HACCP team and the qualified individual have signed off. | Move the trial, not the approval (13.2). |
| Marketing: a campaign needs to go out tomorrow | The mark appears online for a product not on Schedule A, without BRCGS approval. | No mark without Schedule A, BRCGS approval and qualified-individual sign-off (16.1). |
One test covers all of them: did the qualified individual know before it happened? The answer tells you whether your PBMS is a system or a folder in the technical office. What these failures cost once they reach the market, and how to plan a realistic route to the audit, is covered in our companion guide to plant-based claim risk and the certification audit.
Five things to do this week
- Read your policy or commitment letter and confirm it says plainly that the site makes plant-based products to the Standard. If not, rewrite and sign it.
- Put a plant-based question on every change request: has the qualified individual assessed the impact on the claim before the change happens?
- Write down the qualified individual’s authority to stop a supplier, a launch or a production run, and name a deputy who will meet the definition.
- Ask purchasing for every emergency or one-off supplier used in the last year, and check each one was approved by one of the two routes before the material was used.
- Ask marketing for every place the plant-based mark appears, on pack, online and on social media, and match each one against Schedule A and a BRCGS approval.
Related course: BRCGS Plant-Based Issue 1 for Management
A four-hour, self-paced course for directors, owners, site managers and department heads. Five modules, 35 lessons, case studies, knowledge checks and scenario games cover what the Standard expects of senior management, the PBMS you resource, the supply chain and claims decisions you sign off, and how the certificate is won and kept. 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 are senior management’s responsibilities under the BRCGS Plant-Based Standard?
Clause 1.3 asks senior management to build the plant-based management system into the site’s policy, organisation structure, management review and resource planning, and to appoint a qualified individual to oversee it. Leadership also keeps the preconditions in place, from the food safety certificate and an approved Schedule A to paid BRCGS fees, and makes sure budget, schedule, purchasing and marketing decisions do not undermine the claim.
How often must the plant-based management system be reviewed?
At least once a year, and before any change that could affect a plant-based product or claim, such as a new supplier, ingredient, recipe, equipment, packaging or a change in production volume (clause 3.1). The outcome must be built into the system, explained through training and documented, with its validation recorded.
Who must approve a new plant-based product before launch?
The HACCP team and the qualified individual, formally and before the product enters the factory (clause 13.2). The same applies to changes of formulation, packaging or processing method. Labels are re-approved after a formulation change (14.1), and the product must be on the approved Schedule A before it carries the mark.
Can we use a co-packer that is not certified to the Plant-Based Standard?
Not for products you want recognised under the Standard. Clause 6.5 requires each co-manufacturer to hold a valid Plant-Based certificate with the product on its current Schedule A, and there is no alternative route. A food safety certificate alone is not enough.
Does marketing need approval to show the plant-based mark on social media?
Yes. Any reference to the Standard or its trademark, in print, online or on social media, must be approved by BRCGS, follow the plant-based trademark usage guide and comply with the law where the product is sold (clause 16.1). The mark may only appear on products listed on Schedule A.
Does the plant-based management system have to be internally audited every year?
Yes. Clause 5.1 brings it into the scheduled internal audit programme, with frequency set by risk and past performance and every activity audited at least once a year. Include the purchasing, marketing, engineering and HR activities that affect the claim, not only QA.
Next step. If your leadership team needs a shared view of these duties before the next management review, the BRCGS Plant-Based Issue 1 for Management course covers them module by module with South African case studies, and the Introduction to BRCGS Plant-Based Issue 1 course gives the wider team the floor-level picture. For the rest of the 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.