BRC v9 And The Cashew Audit: Twelve Fundamental Requirements, And The Four That Trip Suppliers Up

The BRCGS Global Standard for Food Safety Issue 9 has been the mandatory certification standard for assessed sites since February 2023. Any cashew processing facility audited from that date onward is measured against Issue 9 requirements, regardless of which version their previous certification was held against.

For cashew suppliers serving EU and Japanese specialty buyers, BRC v9 is not optional. For buyers, knowing which of the twelve Fundamental Requirements your supplier is most likely to slip on shifts due diligence from generic to targeted.

The BRC Issue 9 framework contains a large number of requirements across nine clauses. A defined subset is designated Fundamental. The defining property: a major non-conformity against any Fundamental Requirement triggers withdrawal or non-issuance of certification, not just a downgrade. This is the floor that audits cannot move past.

The twelve Fundamental Requirements under Issue 9:

1. Senior management commitment and continual improvement
2. The food safety plan and HACCP
3. Internal audits
4. Management of suppliers of raw materials and packaging
5. Corrective and preventive actions
6. Traceability
7. Layout, product flow and segregation
8. Housekeeping and hygiene
9. Management of allergens
10. Control of operations
11. Labelling and pack control
12. Training

Each is a substantive system requirement, not a checklist item. Issue 9 also expanded the food safety culture assessment as a non-Fundamental but increasingly weighted area, with metrics now required around culture maturity over time.

Across the audits we have visibility into through industry contacts, four areas account for a disproportionate share of major non-conformities against cashew processors specifically:

1. Management of suppliers of raw materials (Fundamental 4)

The single most common slip. Cashew processors typically source raw cashew nut from a mix of domestic farmers, regional traders, and West African origin importers. Each input channel needs a documented supplier approval pathway, risk-based assessment frequency, and a documented exception process when material has to be sourced from an unapproved supplier under urgency.

Common audit findings include: domestic farm sourcing without documented audit equivalence, West African importer relationships without periodic review documentation, or trader sourcing without traceability back to farm origin.

2. Allergen management (Fundamental 9)

Cashew is a tree nut and a top-tier allergen across major regulatory frameworks. Cashew processing facilities that also handle other tree nuts (almonds, hazelnuts, pistachios), peanut, or sesame face cross-contact risk. Even cashew-only facilities require allergen control documentation against external contamination via packaging, ingredient inputs, and visitor protocols.

Common audit findings: incomplete allergen risk assessments for facility layout, missing validation of cleaning between product changeovers, or undocumented training of production staff on allergen procedures.

3. Traceability (Fundamental 6)

Cashew traceability is harder than it looks because of the upstream complexity. A finished kernel lot at the packing stage may have inputs from multiple raw cashew origins, processed through multiple shifts, with intermediate storage before final blending or grading.

Audit expectations: forward and backward traceability achievable within four hours, full chain from raw cashew nut origin through to packed lot and customer shipment, including any intermediate storage and blending events. Common findings include: traceability that breaks at the blending stage, missing intermediate storage lot records, or incomplete origin documentation for raw cashew nut inputs.

4. Control of operations (Fundamental 10)

This is the catch-all that covers aflatoxin sampling SOPs, foreign matter detection, metal detector verification, X-ray operations, and process critical control point management. For cashew specifically, the operational controls most commonly questioned at audit include: aflatoxin sampling frequency and method, metal detector test piece verification frequency, and process step validations for moisture control and steam conditioning.

Ten questions a buyer can ask a prospective or incumbent cashew supplier to surface BRC v9 risk before formal audit cycles align:

1. What was your last BRC v9 audit grade (AA, A, B, C, D), and what was the audit date?
2. How many major non-conformities did you receive, and against which Fundamental Requirements?
3. What was your corrective action timeline, and are any non-conformities still open?
4. What raw cashew nut origin countries did your most recent quarter source from?
5. What is your documented supplier approval process for new raw material sources?
6. What is your facility's allergen management policy regarding tree nut cross-contact?
7. Can you produce a traceability exercise (raw cashew nut origin to packed customer lot) within four hours on a sample lot?
8. What is your aflatoxin sampling method and frequency per lot?
9. What is your metal detector test piece verification frequency?
10. What was your food safety culture self-assessment score in the last twelve months?

Answers that take more than a few business days to produce are themselves an audit signal.

BRCGS has opened public consultation on the next iteration of the Food Safety Global Standard. Suppliers and buyers actively engaged in the standard should monitor the consultation timeline; the consultation phase typically runs several months, followed by an extended adoption window before mandatory effect.

For buyers, this means a stable Issue 9 environment for the next twelve to eighteen months at least, with the option to begin Issue 10 readiness work voluntarily once the draft consultation outputs are published.

Our processing partner factory holds current BRC v9 certification. We can share cert version, scope, and validity dates under NDA at the RFQ stage. The pre-audit checklist above is a question set we ourselves welcome from new buyer engagements; suppliers that respond defensively to this list are typically signalling something.

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Download the BRC v9 cashew pre-audit checklist (10 questions, PDF) — copy and send directly to any prospective supplier.

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