BRCGS traceability requirements,
explained in plain English.

What clause 3.9 actually requires

Clause 3.9 requires the site to be able to trace all raw material product lots (including primary packaging) from their supplier, through all stages of processing and dispatch, to the customer, and vice versa. Both directions, one step up and one step down at minimum, with the internal processing steps fully connected in between.

Three things in the wording catch producers out. First, packaging is included, if your film or labels lot cannot be traced to the batches it wrapped, that is a gap. Second, the trace must pass through processing, which means intermediate stages (silos, brine baths, ageing rooms, rework) must preserve lot identity or document the commingling. Third, the standard requires the system to be tested, not merely described: an annual traceability test achieving full traceability within 4 hours, including a mass balance.

The annual traceability test and the 4-hour rule

The test must take a lot, finished product or raw material, and demonstrate the full chain in both directions, with quantities reconciled. The 4-hour window is measured from nomination of the lot to completed reconciliation. The choice of test lot should vary year to year, and a test that only ever runs the easy product is itself something auditors comment on.

Mass balance is where most tests wobble. The quantity of raw material received must reconcile against the quantity used in production, plus stock, plus waste, plus rework and samples. The standard does not print a universal tolerance figure, your procedure defines one and justifies it, but an unexplained discrepancy is treated as a traceability failure regardless of how fast the trace ran.

The clauses that interlock with 3.9

The evidence pack auditors ask for

Private-label and customer code traceability

If you supply retailers under their own label, your traceability has an extra hop: the retailer's SKU code and description on the dispatch note is not your internal product code. Clause 3.9 does not mention this explicitly, but the vertical audit exposes it immediately, the auditor picks a retailer dispatch line and asks which production batch it was. If the mapping between customer codes and internal codes lives in someone's head, the trace stalls in front of the auditor.

The fix is a maintained, dated customer–SKU mapping: every customer code linked to the internal product it resolves to, with effective dates so historic dispatches still resolve after a spec change. Keystone maintains this bidirectionally, a trace can start from your code or from the retailer's, which is precisely the situation the vertical audit creates.

Can you pass BRCGS traceability requirements traceability on spreadsheets?

Yes, the standard is system-agnostic, and auditors certify spreadsheet-based sites every week. What the standard is not agnostic about is speed, completeness and evidence. The honest questions are: can anyone other than the author run the trace? Does it complete inside 4 hours with a closed mass balance? Do the goods-in, production, rework and dispatch records connect without manual re-keying? If yes, spreadsheets are compliant. If the annual test keeps finding the same gaps, the spreadsheet is the root cause the corrective action never names.

Producers moving to Keystone typically do so after the second or third audit cycle of the same finding, trace time collapses from hours to under 30 seconds because the chain (supplier delivery → intake → batch → dispatch → customer branch) is one connected record rather than five reconciled files.