Last Updated on November 27, 2025 by Melissa Lazaro

Why Record Retention & Traceability Matter in BRC V9

When it comes to BRCGS Version 9, record-keeping and traceability aren’t just paperwork requirements — they’re proof of system control. During an audit, records tell the story of how your site operates: what you did, when you did it, and whether it matched the procedure.

I’ve seen strong traceability systems turn stressful audits into smooth conversations — and I’ve also seen companies lose certification because they couldn’t retrieve evidence fast enough. The difference always comes down to structure and discipline.

This guide walks you through what records need to be kept, how long they should be retained, and what BRC expects during a traceability test or mock recall. If you want confidence — not panic — when the auditor asks for records, this structure will help.

Core Definitions Under BRC V9 – What Counts as a Record & What Traceability Covers

Before diving into rules, it helps to clarify how BRC defines a record.

A record isn’t just a form — it’s evidence of activity. That means:

• CCP monitoring logs
• Training records
• Cleaning records
• Calibration documentation
• Supplier approvals
• Packaging traceability records
• Testing and sampling sheets

Traceability isn’t limited to ingredients either. BRC requires full visibility of:

• Raw materials
• Packaging
• Labelling
• Rework
• Waste streams
• Outsourced processes
• Finished goods

A common misunderstanding is assuming traceability stops at ingredients. But packaging, especially allergen-related or food-contact, is equally important — and yes, auditors will ask for it.

And just to simplify one of the most confused concepts:

1-Up / 1-Down means you must trace one step forward (customer) and one step back (supplier).

Retention Period Requirements – What to Keep & For How Long

Record retention isn’t one size fits all. Some records require longer storage based on product type, shelf life, and legal requirements.

Here’s a practical breakdown:

Record Type	Minimum Recommended Retention
CCP/OPRP Monitoring	Product life + 1 year
Allergen Control Records	Product life + 1 year (often minimum 2 years in practice)
Cleaning & Sanitation Logs	Minimum 12 months
Calibration & Maintenance	Minimum 12 months or cycle duration
Pest Control Records	Minimum 12 months
Training & Competence	Duration of employment + minimum 1 year
Supplier Approvals & Certifications	Must remain current + archived history
Lab Test Results	Minimum 1–2 years depending on risk

A useful approach is to create a Record Retention Schedule — one single index summarizing documentation rules. Auditors appreciate it because it shows governance, not guesswork.

Traceability System Requirements – What BRC V9 Expects Your System to Demonstrate

A traceability system must allow you to prove:

• Where material came from
• How it was processed
• Which batch went into which finished product
• Where that finished product was shipped

To do this effectively, you need:

• Clear batch coding rules
• FIFO management
• Real-time stock control
• Status labels (Approved / Quarantine / Hold / Reject)
• Documented rework handling
• Packaging traceability

One of the most common weaknesses? Rework. If rework isn’t assigned its own batch identity and documented movement, traceability fails — even if everything else is perfect.

Traceability Testing & Mock Recalls – Demonstrating System Effectiveness

BRC requires proof that traceability works, not just exists. That’s where traceability tests and mock recalls come in.

A strong recall simulation should be able to:

• Identify product from batch to customer within 4 hours (under 1 hour is best practice)
• Reconcile all ingredients, packaging, and finished goods
• Produce supporting records instantly — not by searching through piles of paper

What auditors look for isn’t just speed — it’s structure:

• Evidence of communication (internal & external)
• Decision-making records
• Mass-balance calculation accuracy
• CAPA linked to outcomes

A recall drill isn’t a paperwork exercise — it’s a stress test for your compliance system.

Managing Electronic vs. Paper Records – Best Practices & Risks

Many sites now use hybrid systems, and that’s perfectly acceptable — as long as the rules are clear.

Electronic systems must be:

• Secure
• Backed-up
• Version-controlled
• Permission-managed
• Tamper-evident

Paper systems must be:

• Legible
• Signed
• Dated
• Stored safely
• Easy to retrieve

The biggest issue I see with digital systems is editable logs. If someone can change a CCP entry without traceability, it’s not compliant.

If you use digital forms, make sure they’re locked and traceable — think audit trail, not editable spreadsheet.

Common Non-Conformities & How to Avoid Them

Here are the patterns I see repeatedly across audits:

• Missing signatures or dates
• Inconsistent forms across departments
• Outdated supplier documents
• Lost traceability during rework
• No record of sampling or testing verification
• Recall drill results not linked to corrective actions
• No clear retention schedule

A simple rule:

If a record is important to food safety, it must be controlled, complete, and retrievable.

FAQs – Record Retention & Traceability in BRC V9

Do digital signatures count?
Yes — as long as they’re secure, identifiable, and traceable.

How often should traceability tests be carried out?
At least annually, and after major change. High-risk products may require more frequent testing.

Can one traceability system cover multiple product categories?
Absolutely — as long as it’s validated and roles are clearly defined.

Conclusion – What Happens Next

A well-managed record retention and traceability system gives you more than compliance — it gives you confidence. When systems are structured, documented, and tested, audits become predictable and controllable.

If you need a retention index template, a traceability testing script, or a complete documentation pack aligned with BRC V9, I’m happy to help with the next step.