Last Updated on December 1, 2025 by Melissa Lazaro

Why Supplier Agreements Need Updating for BRC V9

One of the biggest questions I hear from teams preparing for BRC V9 is: “Do we really need to change our supplier agreements?”

The short answer is yes — especially if those agreements were originally built around BRC V8 or haven’t been updated in a while. BRC V9 doesn’t just refine requirements; it clarifies expectations around allergens, cybersecurity, food defence, product integrity, and change management.

Updating your supplier agreements isn’t about paperwork — it’s about protecting your supply chain and closing compliance gaps before an auditor or incident exposes them.

By the end of this, you’ll know exactly what needs updating, what to include, and how to roll out these changes without damaging supplier relationships or slowing down production.

Review What BRC V9 Expects from Supplier Agreements

Let’s start with the core expectation: supplier agreements should clearly define responsibilities, verification requirements, communication timelines, and evidence expectations. BRC has tightened language around risk-based commitments — meaning “assumed compliance” isn’t enough anymore.

Key areas now emphasized include:

• Clear communication triggers (reformulation, recalls, supplier changes)
• Stronger allergen and labelling accuracy responsibility
• Clear cybersecurity expectations
• Demonstrable food defence and fraud prevention measures
• Defined traceability and recall obligations

Pro Tip

Before updating your templates, review your supplier performance data. Agreements should reflect risk — not a generic one-size-fits-all requirement list.

Common Mistake

Only updating the paperwork — but never communicating expectations or resourcing follow-up.

A real example: a supplier signed a new allergen clause but hadn’t updated their cleaning validation in three years. The site assumed compliance — until the audit.

Key New Requirements to Include in Supplier Agreements Under BRC V9

This is where the updates become practical. Let’s break down what needs clearer language in the agreement.

1. Cybersecurity Requirements

This is new for many companies. BRC now explicitly expects suppliers to protect digital systems that store quality, formulation, or traceability data.

What to include:

• Access control expectations
• Backup and recovery requirements
• Notification timelines for breaches
• Minimum IT safeguards

You don’t need enterprise-level cybersecurity — but you do need documented expectations.

2. Strengthened Allergen and Label Control Commitments

BRC V9 expects better allergen management — especially around reformulation and label changes.

Your agreement should require suppliers to:

• Declare allergens accurately
• Notify the site before any formulation changes
• Provide verification evidence (COAs, allergen maps, swab validation, etc.)
• Ensure labelling accuracy and traceability

A signature alone won’t protect you — evidence will.

3. Food Defence & Fraud Prevention Expectations

Supplier vulnerability assessments must now be aligned with current risk levels — not outdated assumptions.

Required elements may include:

• TACCP/VACCP documentation
• Frequency of review
• Preventive controls
• Incident communication timelines

Common Gap

Supplier has a vulnerability assessment — but no verification or review record.

4. Traceability, Recall, and Change Notification Rules

This is one of the most overlooked updates.

Agreements should define:

• Recall response times
• Evidence required during product withdrawals
• What qualifies as a “material change”
• How quickly the supplier must communicate updates

If recall communication still depends on phone calls or WhatsApp messages — you’ll want to tighten that.

5. Testing, Certificates & Documentation Renewal Frequency

BRC V9 places more weight on evidence maturity and review frequency.

Your agreement should clarify:

• Required certificates (GFSI, compliance declarations, COAs)
• Shelf-life verification evidence
• Micro, chemical, allergen testing schedules
• Document renewal timelines (often annually or based on risk)

How to Update Agreements Without Damaging Supplier Relationships

Rolling out changes shouldn’t feel like a legal ambush.

A smoother approach:

1. Communicate intent first — explain BRC changes, not just demands.
2. Share a transition timeline — avoid “sign this in 48 hours” pressure.
3. Discuss challenges early — especially with smaller or high-risk suppliers.
4. Offer support tools — a FAQ sheet, updated spec process, or webinar.

One site held a 30-minute supplier briefing — and compliance improved faster than emailing revised contracts. Sometimes clarity beats a signature.

Pro Tip

Prioritize high-risk suppliers first, then move through medium and low tiers.

Verification & Monitoring: Making Sure Agreements Aren’t Just Paper

Once updated agreements are signed, the work isn’t finished.

You need a monitoring plan that covers:

• Supplier audits
• Evidence submissions
• Performance reviews
• Non-conformance responses
• Recall participation
• Trend analysis

A signed document proves commitment — verification proves compliance.

Template Format: What Your Updated Supplier Agreement Should Include

Here’s a simple structure (not legal language — just functional framework):

Section	Requirement Summary	Evidence Supplier Must Provide	Frequency	Verification Method	Notes

Short, clear, and actionable works best. Legal jargon doesn’t improve compliance — clarity does.

FAQs

1. Do all suppliers need updated agreements?
Yes — but rollout priority should follow risk-tiering.

2. What if a supplier refuses new clauses?
Reassess risk, look at mitigation options, and discuss alternatives. Documentation must reflect your response.

3. Can we keep the old agreement if nothing has changed?
Only if reviewed, documented, and aligned with V9 requirements — and evidence shows ongoing compliance.

Conclusion: The Next Step in Your Supplier Compliance Journey

Updating supplier agreements for BRC V9 isn’t just a requirement — it’s a safeguard. It protects your products, your customers, and your certification. The strongest sites don’t just get signatures — they build transparency and shared accountability with their supply chain.

Now that you understand what needs updating, the logical next move is creating your updated supplier rollout plan and aligning it with supplier risk-tiering and verification procedures.