Last Updated on December 1, 2025 by Melissa Lazaro

What Early Implementers Are Seeing and Why It Matters

When the first companies began transitioning to BRC V9, a lot of people expected the shift to feel like a minor revision. On paper, it looked manageable — a few strengthened clauses, clearer expectations, and some new elements around cybersecurity and culture.

But once implementation began, a different story emerged.

Working alongside early adopters has made one thing very clear: the level of evidence, consistency, and risk-based thinking required under V9 goes deeper than many anticipated. The companies that approached the transition strategically moved through it smoothly. The ones who treated it as a quick document update ran into avoidable hurdles.

By reading through these lessons, you’ll get a clear picture of what worked, what didn’t, and how to avoid the stress others experienced.

Lesson #1: Updating Documents Was the Easy Part — Implementation Took Real Effort

Most early adopters made the same assumption:
“Once documents are updated, we’re ready.”

But when internal audits started, gaps emerged. A common pattern popped up: documents said one thing, but floor practices hadn’t changed yet.

Why? Because operators were still using old forms, supervisors weren’t trained on new requirements, or procedures were updated in isolation — without real adoption.

What worked instead:

• Updating documents
• Training based on real tasks
• Verifying competence — not just attendance
• Auditing implementation within 30–60 days

One facility avoided multiple non-conformities simply because they ran a follow-up audit after implementation and corrected gaps early.

Lesson #2: Food Safety Culture Needed More Than a Policy Update

Food safety culture is now a measurable requirement — and that surprised many teams. Early adopters discovered that writing a policy wasn’t enough.

Auditors asked for:

• KPIs
• Evidence of engagement
• Competency feedback loops
• Trends and measurable improvements

The sites that succeeded tied culture into their existing activities — toolbox talks, audit feedback loops, onboarding, and performance reviews.

The ones who treated it as a standalone task struggled.

Lesson #3: Allergen and Label Control Requirements Took More Work Than Expected

This was the area that caught the most teams off guard.

Not because allergen controls were new — but because the level of verification and traceability expected under V9 is far more detailed.

Common gaps found:

• No trending of allergen swab results
• No documented rationale for cleaning validation
• Outdated supplier allergen declarations
• Label change control not fully documented

One site reduced allergen-related issues significantly by building a more structured change-control and label-verification process — instead of relying on memory and habit.

Lesson #4: Cybersecurity Requirements Were the Most Overlooked

Cybersecurity felt like a “non-food” requirement at first, so many teams put it at the bottom of the priority list.

But when auditors started asking about:

• Access controls
• Backup testing
• Password rules
• Breach response protocols

— it became clear this wasn’t optional.

The sites that performed best began with simple wins:

• Unique login access
• Role-based permissions
• Regular password resets
• Evidence of backup testing

They focused on practicality — not perfection.

Lesson #5: Supplier Agreements Took Longer to Update Than Planned

Supplier compliance was another underestimated area. Updating agreements, gathering new evidence, and communicating new expectations took significantly longer than expected — especially with suppliers outside GFSI-recognized systems.

The biggest delays came from:

• Slow supplier responses
• Confusion about new requirements
• Lack of supporting evidence (TACCP/VACCP, cybersecurity, allergen maps)

Sites that built a structured rollout and supported suppliers — instead of simply emailing new agreements — transitioned faster and encountered fewer surprises.

Lesson #6: Internal Audit Tools Needed Full Redesign — Not Minor Adjustments

A surprising number of early adopters tried reusing their V8 checklists. But because V9 strengthens expectations around risk, evidence, and culture, those outdated checklists created blind spots.

Strong transition audits focused on:

• Observing behaviors
• Reviewing evidence maturity
• Confirming decision-making rationale
• Validating competence — not just training records

The biggest wins came from internal audits done well before certification — not weeks before.

Lesson #7: Sites Already Working Risk-Based and Evidence-Based Before V9 Transitioned Smoothly

This pattern stood out immediately.

Companies that already:

• Used trending
• Documented risk rationale
• Ran verification with purpose
• Treated audits as process validation — not procedure checking

… transitioned with less stress.

For them, V9 wasn’t a major shift — it was a continuation of good practice.

Summary of Common Pitfalls from Early Adopters

Here’s what repeatedly caused avoidable issues:

• Assuming documentation updates were enough
• Ignoring follow-through on training and competency
• Treating culture and cybersecurity as low priority
• Delaying supplier communication
• Using outdated audit tools
• Waiting too long for internal verification

What Early Adopters Recommend Doing First

Based on patterns seen across multiple sites, the most effective sequence was:

1. Run a detailed gap-analysis
2. Prioritize high-risk updates (allergens, cyber, supplier agreements)
3. Update training and competency evidence
4. Revise internal audit tools to align with V9
5. Conduct a comprehensive readiness audit

This approach avoids last-minute panic and builds confidence across the system.

FAQs

1. Is BRC V9 harder than V8?
Not harder — but more precise. Evidence and verification matter more now.

2. How much time should we plan for the transition?
Anywhere from 8–16 weeks depending on implementation maturity and supplier responsiveness.

3. Can we reuse existing forms and checklists?
Yes — if they’re updated to reflect V9 expectations. Using old tools leads to blind spots.

Conclusion: Learn From Others — Don’t Repeat Their Challenges

Early adopters have shown that transitioning to BRC V9 can be smooth — if it’s done intentionally. The companies who approached it with a risk-based, evidence-driven mindset saw the transition as an evolution, not a disruption.

If you’re starting or midway through the shift, your next move should be running a structured transition review and updating your verification tools.