BRCGS Consumer Products Issue 5: the draft is out, with 10 key changes
The first step toward the long-awaited new edition of the BRCGS Consumer Products standard has been taken. The draft of BRCGS CP Issue 5 was opened for review by professionals on 11 December 2025. Industry stakeholders can submit their comments on the draft through the BRCGS website until 22 January 2026. The final standard is planned for publication in September or October 2026.
So what fundamental changes will the new issue bring to your management systems? Here are the 10 key changes coming with BRCGS CP Issue 5:
- Merged standards: one framework The most notable change in the new issue is that the previously separate General Merchandise and Personal Care and Household standards have been brought together into a single structure.
- From two levels to one The split between “Higher Level” and “Foundation Level” used in Issue 4 has been removed entirely. The new issue defines a single, standard level for all sites.
Enhanced hygiene conditions (Clause 7)
With the GM and PCH standards merged, specific requirements have been introduced for hygiene-sensitive products. Clause 7, Enhanced Hygiene Conditions, will become mandatory when:
- The legislation of the country of manufacture or supply sets microbiological criteria.
- A risk assessment finds that the product supports microbiological growth and could pose a risk to consumer health (the requirements are set out in Appendix 2).
- Clause 8 for traded products To align with other current BRCGS standards, the scope for traded products has been added to the standard as Clause 8.
- A holistic approach to risk analysis (Clause 2) Product risk analysis and process risk analysis, covered in separate clauses in Issue 4 (Clause 2 and Clause 6), have been merged under a single heading in Clause 2 in the new issue.
- Product safety culture and product defense As in IFS HPC and other modern BRCGS standards, requirements for a product safety culture program and product defense are now an integral part of Issue 5.
- Product vulnerability management (Clause 5.2) Product vulnerability management, which was procedure-based in the previous issue, now appears as a more comprehensive section under Clause 5.2. Sites have been given until April 2028 to comply with this clause and include it in their audits.
- Prerequisite programs (PRPs) The concept of a prerequisite program, not explicitly defined in Issue 4, has been added to the standard, with detailed lists of programs under this heading.
- Allergen management (Clause 4.12) With Issue 5, allergen control is covered in detail as an entirely new, standalone section (Clause 4.12).
- Workwear and hygiene rules For sites manufacturing microbiologically sensitive products, the rules for laundering workwear have been tightened. Laundering must now be done either in-house or by a professional third-party service provider.
Important reminder: the deadline for reviewing the draft standard and submitting comments is 22 January 2026.
You can access the BRCGS CP Issue 5 draft here: