BRCGS Position Statements set out how the scheme owner interprets its own requirements, including the allergen and gluten free ones. ASC runs virtual BRCGS implementation training on scheduled and in-house dates. The session announced in this post ran from 8 to 10 September 2026, so ask us for the next dates.
Codex adopted a precautionary allergen labelling annex to CXS 1-1985 at CAC49 in July 2026. It sets reference doses and an action level formula: above the action level a may contain statement shall be used, and at or below it a precautionary statement should not be used. Codex is not South African law. Regulation 43 of R146 of 2010 remains the South African allergen declaration rule and carries no precautionary labelling provision at all, which is why the annex reaches you through an export customer, a certification scheme or an importing authority instead. The full analysis is in the Codex precautionary allergen labelling annex and the reference doses.
- If you are certificated to a BRCGS gluten free scheme: the position statements reinforce requirements already in place, namely robust allergen segregation, validation and verification, with no precautionary gluten statement alongside a gluten free claim. Read the requirement off the position statement document itself before you change a label.
- If you are certificated to another GFSI scheme: these statements are BRCGS interpretations of BRCGS requirements and do not bind you. The underlying question does apply to every site, which is whether your allergen risk assessment and testing strategy still support the statements printed on your labels.
For the official interpretation of how allergen and gluten-free requirements apply under BRCGS, see our BRCGS Position Statements page, where the current Position Statement documents are available to download directly.
Upcoming Training: Virtual Implementation of BRCGS — 8–10 September
With the new Position Statements now in force, there’s no better time to get your team hands-on with the practical side of BRCGS implementation. Join our virtual training running from 8–10 September, where we walk through building and maintaining a certification-ready system — from documentation through to audit preparation.
3-day virtual classroom, 8–10 September 2026