BRCGS Issue 9
Traceability software built for BRCGS Issue 9. Designed against §3.9 / §3.11. Tested in real audits.
BRCGS Issue 9 raised the bar on traceability. §3.9 demands a verified system that links inputs to outputs end-to-end. §3.11 demands traceability tests at frequencies you specify, with documented results. Keystone is built to make both painless.
Home › BRCGS Traceability Software (Issue 9)
Proof points
In one glance.
- Designed against BRCGS Issue 9 §3.9 / §3.11 traceability clauses
- Mock-recall in 90 seconds — signed PDF for audit
- Both directions: upstream supplier chain + downstream customer chain
- Audit-trail of every traceability test run
What §3.9 and §3.11 actually require
The shorthand BRCGS auditors actually look for.
§3.9 — your traceability system must link inputs (raw materials, packaging, primary processing aids) to outputs (finished goods), in both directions, with a defined response time. §3.11 — you must test the system at documented intervals, with results retained. Most producers fail not because they can't trace, but because they can't prove the test was run and the result was correct.
How Keystone maps to the clauses
Clause-by-clause coverage.
- §3.9.1 — Identification of incoming materials — Supplier deliveries are first-class entities; every batch is linked to the deliveries that fed it.
- §3.9.2 — Identification of finished products — Every dispatch line carries its batch ID. Reverse-trace works from any customer reference.
- §3.11 — Traceability tests — Built-in mock-recall feature with scheduled prompts and signed-PDF output.
- §3.11.3 — Test result records — Every test logged with who, when, target trace time, actual trace time, result.
The 4-hour test
The annual test — and the vertical audit — without the scramble.
Issue 9 expects the traceability test to achieve full traceability, including a mass balance, within 4 hours of the lot being nominated — and most auditors additionally run a live vertical audit, picking a lot during the visit and watching you trace it. Keystone changes the shape of both: the chain and quantities render in under 30 seconds, so the 4-hour window is spent on the parts that deserve attention — verifying the waste and sample logs, closing the reconciliation, writing honest findings. The vertical audit becomes a screen-share. We've written up what clause 3.9 actually asks for, in plain English, as a free guide.
Beyond §3.9
The interlocking clauses your traceability carries.
- §3.5 — Supplier approval & raw materials — Goods-in records with supplier lot codes and linked COAs are the upstream anchor of every trace. Keystone captures them at intake, including packaging deliveries.
- §5.4 — Authenticity, claims & chain of custody — Provenance and claim substantiation depend on lot-level lineage. Versioned specs mean historic batches resolve against the spec current when they were made.
- Rework & intermediates — Silo runs, brines and rework carry their own lot identity linking parent and child batches — the commingling points where spreadsheet mass balances die.
- Attributability — Every record signed — who, when, why — and protected from silent edits. Editable history is a credibility problem in front of any certification body.
FAQs
Frequently asked.
Is Keystone a BRCGS-approved software?
BRCGS does not currently issue "approved software" certifications for traceability systems — they audit the producer's outcomes. Keystone is designed against Issue 9 clauses and we're happy to walk an auditor through the system on a discovery call.
What about BRCGS Issue 10?
Issue 10 is currently in consultation. We monitor BRCGS draft revisions and update the platform ahead of effective dates.
Do you provide audit-prep support?
Yes — included in Standard implementation. We'll run a mock audit on your live data 30 days before your BRCGS visit.
Can we restrict who can run a recall test?
Yes — role-based access. Recall execution is typically restricted to QA Manager + nominated deputy.