What Buyer Audits Say About CCTV: SMETA, BRCGS, Retailer Codes
No, as of 15 Oct 2026: none of the nine buyer-audit documents we read (SMETA 7.0, amfori BSCI, BRCGS Food Safety Issue 9, SLCP, Walmart and Amazon codes) makes CCTV mandatory. BRCGS asks you to monitor areas of significant food-defence risk without naming cameras. Only SMETA's clause 1.D names CCTV, and it limits it.
Last checked: 15 Oct 2026
By the Mama Editorial Team, for Indian export and food units told "the auditor wants cameras". Published standard texts only. Not legal advice.
Verified against
- Sedex, SMETA 7.0 Auditor Manual Annex 4: The SMETA Workplace Requirements, August 2025 v1.1 (PDF, VWA copy)
- Sedex, SMETA 7.0 Annex 5: Checklists, August 2025 v1.1 (PDF, VWA copy)
- Sedex, Minimum Requirements, version 1.2, April 2026 (PDF, VWA copy)
- amfori, amfori BSCI Code of Conduct 2021 and amfori BSCI audit rating overview, December 2023
- BRCGS, Global Standard Food Safety, Issue 9, August 2022, ISBN 978 1 78490 447 0 (PDF, Camposol copy), pp. 42–43 and Part III
- BRCGS, F926: Position Statements for Issue 9, version 4 of 27 Apr 2026, and Key Changes – Position Statements of 22 May 2026 (F926 PDF, Key Changes PDF, consultancy copies)
- SLCP, Converged Assessment Framework flat file v1.7.1 (alpha 42), from the SLCP Helpdesk download page; Worldly, CAF 1.7.1 updates
- Walmart, Standards for Suppliers, updated February 2024
- Amazon, Supply Chain Standards, effective 19 Jan 2023 and Supplier Manual
- Intertek, Workplace Conditions Assessment page
- CBP, CTPAT Minimum Security Criteria – Foreign Manufacturers, October 2021, criteria 9.12–9.16
- Checked 15 Oct 2026. Each document was searched for "CCTV", "camera", "surveillance", "closed circuit" and "video".
Standard by standard: is CCTV required?
| Standard (version) | Clause | What the text says about cameras | CCTV verdict | Source (checked 15 Oct 2026) |
|---|---|---|---|---|
| SMETA 7.0 Workplace Requirements (Aug 2025 v1.1) | 1.D, under ETI clause 1 "Employment is freely chosen" | "Ensure that any surveillance (primarily human but also electronic, such as CCTV or facial recognition), if used, is not excessive or for the purpose of controlling or intimidating workers." | Not required; use is limited | Sedex Annex 4 |
| SMETA 7.0 Checklists (Aug 2025 v1.1) | Opening and closing meeting agendas | No mention of CCTV, cameras or video | Not mentioned | Sedex Annex 5 |
| Sedex Minimum Requirements (v1.2, Apr 2026) | 6.2.6 "Use of Pictures" | Covers the auditor's own photos, which "shall not infringe privacy or data protection requirements"; nothing on site CCTV | Not mentioned | Sedex Minimum Requirements |
| amfori BSCI Code of Conduct 2021 and rating overview (Dec 2023) | Rating question 13.4 | Personal information must be processed "in accordance with privacy and information security laws"; no camera wording | Not mentioned | amfori |
| BRCGS Food Safety Issue 9 (Aug 2022) | 4.1.4 site access | Access "is controlled. A visitor recording system shall be in place." | Not named | BRCGS Issue 9, p. 42 |
| BRCGS Food Safety Issue 9 | 4.2.2–4.2.4 food defence | Threat assessment, a food defence plan, and areas of significant risk "defined in the food defence plan, monitored and controlled", including "external storage and intake points" | Not named; monitoring method left to the site | BRCGS Issue 9, p. 43 |
| SLCP CAF v1.7.1 (used by Higg FSLM) | All questions; guidance to wt-for-2 | No question on CCTV; "camera" appears only as an e-waste item. The forced-labour question wt-for-2 lists "constant surveillance" among coercive tactics | Not required; constant surveillance counts against you | SLCP flat file v1.7.1 |
| Walmart Standards for Suppliers (Feb 2024) | "Observe Trade, Sanctions, and Security Laws" | "Establish controls to secure the supply chain"; where Walmart is importer of record, follow C-TPAT and AEO principles | Not named; points to C-TPAT | Walmart |
| Amazon Supply Chain Standards (eff. 19 Jan 2023) | Section 5 "Privacy and Data Protection" | "Suppliers should not act arbitrarily to interfere with a worker's privacy" | Not mentioned | Amazon |
| Intertek WCA | Protocol not published | Public page lists labour practices, health and safety, environment, business ethics | Not in public material | Intertek |
| C-TPAT MSC (Oct 2021) | 9.13 | "If camera systems are deployed, cameras must be positioned to cover key areas of facilities that pertain to the import/export process." | Conditional "must" once cameras exist | CBP |
A rule that makes cameras a condition of a SMETA, amfori, BRCGS, SLCP, Walmart or Amazon audit was not found in any of these texts (checked 15 Oct 2026).
What BRCGS actually asks for
BRCGS Food Safety Issue 9, clause 4.2.2, requires "a documented risk assessment (threat assessment) of the potential risks to products from any deliberate attempt to inflict contamination or damage", covering internal and external threats.
The output is a food defence plan, reviewed "at least annually" and whenever a new risk emerges or a food defence incident occurs (clause 4.2.2, Issue 9, August 2022).
Clause 4.2.3 says that where prevention is "not sufficient or possible", "systems shall be in place to identify any tampering", and those controls must be monitored, documented and reviewed at least annually.
Clause 4.2.4 says areas where a significant risk is identified must be "defined in the food defence plan, monitored and controlled"; this is not the same as BRCGS's "high-risk" production zone. A camera is one way to monitor an intake bay; a locked door with a key log, a seal register and a supervised gate are others. The standard leaves the choice to your threat assessment.
The only cameras the Issue 9 text names are the webcams used in BRCGS's blended (remote) audits, where "Use of webcams/cameras shall be agreed" and live video "shall not be recorded" (Part III).
BRCGS's position statement F926, version 4 of 27 Apr 2026, effective 10 Aug 2026, adds one requirement change, to clause 7.4.2 (protective clothing and footwear); its other statements cover audit scheduling and certification bodies, and none touches sections 4.1 or 4.2.
Where cameras can count against you
SMETA 7.0 is the only document here that names CCTV, and it does so as a limit. Under Workplace Requirement 1.D an auditor can raise a finding if surveillance is "excessive" or used to control or intimidate workers.
SLCP points the same way without naming CCTV: its CAF v1.7.1 guidance to forced-labour question wt-for-2 lists "constant surveillance" as a coercive tactic (checked 15 Oct 2026).
A camera aimed at the union notice board or at workers on a break is the kind of use 1.D lets an auditor question. Cameras inside washrooms, changing rooms or a creche are a separate matter: Indian law puts them among the places a camera may never go.
amfori question 13.4 and Amazon's Section 5 both tie personal data to "privacy and information security laws". In India the matching law is the Digital Personal Data Protection Act, 2023; our DPDP and worker CCTV page covers what it asks of footage of people and when its duties apply.
Sedex auditors must obscure "workers' face, full name or other ID information" in audit photos (Minimum Requirements v1.2, 6.2.6); take the same care with footage you show.
Where a camera genuinely helps an audit
| Audit point | Clause | What footage can show | What it cannot show |
|---|---|---|---|
| Intake and external storage monitored | BRCGS 4.2.4 | Who entered the bay, and when, against the gate register | Whether a sealed drum was tampered with inside |
| Visitors and contractors controlled | BRCGS 4.1.4 | Entries that are missing from the visitor book | Whether the visitor was briefed on site rules |
| Export loading and sealing | C-TPAT 9.13, 9.15 | Container sealing, with written random reviews | Cargo condition after the truck leaves |
| Hours on the line | SMETA ETI clause 6 | Whether a line ran after the shift bell (line level, not per worker) | Who worked, or whether overtime was voluntary and paid |
In every row the camera is evidence for a control you already run, not the control itself.
What to ask your buyer or auditor
If someone says "CCTV is mandatory for this audit", ask for the clause number and the document version. None of the nine texts above has one (checked 15 Oct 2026).
Ask whether the requirement comes from the buyer's own contract, vendor manual or security questionnaire. A buyer can write cameras into a purchase contract even though its published code does not.
For the Indian legal rules on factory cameras, which are separate from any buyer audit, use the factory CCTV compliance checklist.
If you ship to a US importer, read the C-TPAT camera criteria: Walmart's code sends suppliers there when Walmart is importer of record.
For food units, the FSSAI side is on our food processing camera page; BRCGS adds the food defence plan, not a camera mandate.
Where Mama fits
Mama reads the cameras a plant already has and sends the owner a short note each morning on machines and lines: which ran, which sat idle, and where hours leaked. It watches machines and flows, not named people. Mama does not produce audit evidence or replace your registers. Leave an email or phone in the form below.
FAQ
Is CCTV mandatory for BRC (BRCGS) food certification?
No. BRCGS Food Safety Issue 9 requires a threat assessment, a food defence plan and monitoring of areas of significant risk, including intake points (clauses 4.2.2–4.2.4), but the requirement text never names CCTV (checked 15 Oct 2026).
Does SMETA require CCTV in the factory?
No. SMETA 7.0's Workplace Requirements mention CCTV once, in 1.D, to say surveillance "if used" must not be excessive or intimidating. The Annex 5 checklists do not mention cameras (checked 15 Oct 2026).
Can my buyer still insist on cameras?
Yes, through its own contract, vendor manual or security programme such as C-TPAT. That is a commercial term, not part of SMETA, amfori BSCI or BRCGS, so ask for it in writing with the exact areas to cover.