The release of the latest BRCGS annual report has prompted the usual interest in the most common food safety non-conformances[1]. These reports are useful because they give us a view of what auditors are finding across a very large number of certified sites. They also give manufacturers, retailers, brand owners and insurers an opportunity to reflect on where compliance pressure is showing up most often.
The latest food safety findings are not especially surprising. The same broad themes have appeared repeatedly in recent years: cleanliness, hygienic design of equipment, chemical control, and site fabric issues such as walls, doors, floors and general maintenance. The order may move around slightly from year to year, but the underlying pattern is familiar.
Source: RQA Group analysis of BRCGS official annual reports, 2021[2], [3]2022, 2023[4], 2024[5], 20251.
That does not mean the findings are unimportant. Far from it. Cleanliness, hygienic design, chemical control and factory fabric all matter. They can influence contamination risk, pest risk, allergen control, foreign body risk, cleaning effectiveness and the general standard of operational discipline on site. These are not just cosmetic issues.
Why the same issues keep appearing
However, we should be careful not to over-interpret the ranking as though it reveals something entirely new about food safety performance. In many ways, it reflects a long-running shift in audit focus. Food safety audits have, quite rightly, moved away from being overly paperwork-led exercises and towards greater emphasis on actual factory conditions. In simple terms: do not just sit in a meeting room and check the documents – go and look.
That “go and see” principle will be familiar to anyone who has worked with Gemba walks, lean tools or practical operational review. When auditors spend more time walking production, storage and engineering areas, they are more likely to identify visible site-standard issues. Damaged walls, worn floors, poorly fitting doors, ageing equipment, poor hygienic design and cleaning weaknesses are all relatively easy to observe. They are also common challenges across many different types of food manufacturing sites, so it is natural that they appear often as recurring themes.
The more interesting question is why these issues remain so persistent and, more importantly, what the true root cause may be.
Few food businesses want to operate from tired buildings, damaged finishes or ageing equipment. Most technical and operational teams would prefer clean, modern, well-designed facilities that are easy to maintain and easy to clean. But food manufacturing operates under intense commercial pressure. Customers want safe, high-quality food at competitive prices. Retailers and food service customers often apply significant margin pressure. At the same time, manufacturers are dealing with rising labour, energy, ingredient and compliance costs.
Replacing a floor, upgrading drainage, redesigning equipment or refurbishing a high-care area is rarely a small job. It can involve major capital expenditure, production downtime, temporary loss of capacity and major disruption to production and supply. In that context, the root cause of recurring fabric and equipment issues may not be lack of awareness. It may be investment, prioritisation and commercial reality.
Certification is useful, but still a snapshot
For manufacturers, retailers and insurers, the real value of BRCGS data may therefore not be in the ranking of individual clauses alone. It may be in using audit outcomes as one part of a wider view of risk.
Certification audits are valuable, but they are not perfect. They inevitably involve an element of preparation, even when unannounced. Sites know the standard. They know the likely areas of focus. They know the types of evidence that will be reviewed. That does not make certification meaningless, but it does mean we should avoid treating an audit grade as a complete picture of a site’s true risk profile.
In practice, many of us who have worked in retail, manufacturing, auditing or incident response have seen sites with strong certification grades that still have significant issues requiring urgent escalation. Sometimes the gap between the certificate and the operational reality can be very uncomfortable. That is not an argument for abandoning certification schemes. They have an important role. But it is a reminder that they are not the golden panacea they are sometimes hoped and/or believed to be.
Standard owners and certification bodies will continue to update requirements, audit techniques and areas of focus. That is necessary. But it is also an impossible riddle to solve completely. Standard development will always involve a range of perspectives, including manufacturers, retailers, service providers, certification bodies and technical specialists. Each brings useful experience, but also a particular lens. Those dealing with incidents, recalls and operational failures may see risk differently from those primarily focused on routine compliance.
A current certificate is useful, but it is still a snapshot. A stronger signal may be the direction of travel. Has the site’s grade changed? Are non-conformances increasing? Are repeat issues appearing? Has certification scope changed? Has a previously stable supplier started to show deterioration? These movements may tell us more than the grade itself.
Over-reliance on audits and their results is not a true reflection of the nature, culture and inherent risk within a business. We have seen that for years, and it is reflected in the repetitive nature of these public reports. The same issues keep appearing because the same pressures, limitations and behaviours continue to exist.
The real question is not just whether a site is certified to an acceptable level. It is whether the assurance picture is stable, improving or starting to move in the wrong direction.
From certificate on file to live risk signals
Going part way towards answering this, scheme owners such as BRCGS have started to provide access to tools that may feed better into risk-based models, rather than relying on absolute, point-in-time data. This is where tools such as BRCGS Directory Pro[6] become more interesting, but at a cost. BRCGS describes Directory Pro as providing instant visibility of live certification data across a BRCGS supplier network, with functionality to track certification status, access certificate data and enable live alerts for tracked sites.
Used well, this type of supplier-certification data may help businesses move beyond a static “certificate on file” approach and towards a more dynamic model of assurance. For food manufacturers and brand owners, that could inform supplier segmentation, audit frequency, technical review and escalation. For insurers, it could become one input into a broader risk view alongside product type, process complexity, claims history, recall exposure, allergen profile, management controls and previous incident performance. Many other (typically paid for) data sets which could be equally or more useful also exist and need careful scrutiny to assess which, if any, are of value however on a case by case basis.
The reporting gap
The same applies to confidential reporting routes. Mechanisms such as TellBRCGS[7] are useful in principle because some of the poorest behaviours and weakest controls are seen outside formal audit windows. Customer visits, technical reviews, incident investigations and routine supplier interactions can all reveal issues that may not be visible during an announced audit.
The challenge is whether people feel able to use those routes. Retailers, and in some cases large customers, may be more prepared to escalate serious concerns, particularly where there is a clear mismatch between a site’s certification status and what has been observed on the ground. Manufacturers may find that more difficult. They may worry about damaging supplier relationships, triggering commercial consequences, or being seen to report another business.
Even where reporting routes are designed to be confidential or anonymous, the food industry can be a small world. In some situations, it may not be difficult for people to infer where a concern has come from. It would therefore be optimistic to assume that confidential reporting mechanisms will capture a full and representative picture of industry concerns. As a result, issues may be discussed informally, including through the industry grapevine, but not always escalated through the channels designed to capture them.
That is an important cultural point, and we all know how crucial culture is. A reporting mechanism only adds value if there is enough trust, confidence and maturity for people to use it. The industry may not be fully there yet. As much as we may want better data sharing, voluntary reporting alone is unlikely to create a level landscape for all involved.
Final thoughts
Ultimately, the BRCGS report is a useful reminder that food safety assurance is not just about holding a certificate or passing an annual audit. The recurring non-conformances tell us that practical factory standards still matter. The wider developments in certification visibility and reporting also point towards a more dynamic way of thinking about risk.
For manufacturers, retailers and insurers, the opportunity is to look beyond the audit grade and ask better questions. What is changing? What is repeating? What is deteriorating? What is not being captured in the certificate alone?
Because in food safety and recall risk, the most useful signal is often not the position at a single point in time. It is the direction of travel.
If you would like any support with anything you’ve read in this article, RQA specialise in developing bespoke programs which go beyond the routine. Simply get in touch.
[1] brcgs.com/media/bnqbawek/brcgs-annual-report-2025-26-final.pdf
[2] brcgs.com/media/2170658/brcgs-compliance-report-2021.pdf
[3] brcgs.com/media/2174286/brcgs-compliance-report-2022-final.pdf
[4] brcgs-annual-business-report-2023-24-screen-ready-1.pdf