14. Oct 2022

New developments for Food Businesses

The new EU Guideline on the implemen­tation of Food Safety Management Systems published

The Commission Notice 2022/C 355/01 on the implementation of food safety management systems covering Good Hygiene Practices and procedures based on the HACCP principles, including the facilitation / flexibility of the implementation in certain food businesses was published on 16 September 2022 in the Official Journal of the European Union.

Following changes in legislation, the revision of the Codex Alimentarius general principles of food hygiene and the revision of international standards, in particular ISO 22000, a revision of the 2016 Notice was considered appropriate. This Notice, which replaces the 2016 Notice, aims to facilitate and harmonize the implementation of EU requirements on Good Hygiene Practices (GHP) and procedures based on the HACCP-based procedures as parts of Food Safety Management Systems (FSMS). As a general guidance, it is primarily intended for competent authorities to create a common understanding of the legal requirements and for food businesses to provide support in implementing the EU regulations after company-specific adaptions. It also provides tools and examples to all food business operators of how to implement the EU requirements. Furthermore, practical guidance is provided on the following topics:

  • Relevant legislation, link between GHP, PRPs and HAAC-based procedures as parts of the FSMS; relationship with international standards and training and the guides to GHP;
  • Implementation of GHP including the flexibility provided for certain food establishments by EU legislation related to their implementation (Annex I);
  • Implementation of HACCP-based procedures including the flexibility provided for certain food establishments by EU legislation related to their implementation (Annex II);
  • FSMS Audits (Annex III).

Further amendments and practical recommendations

Particular importance is placed on flexibility provided for in the application of GHP and HACCP-based procedures, taking into account the nature of the activity and the size of the establishment.

In addition to detailed definitions, this revised guide provides practical explanations and recommendations for the implementation of legal requirements. The new obligations regarding allergen management, food safety culture as well as the redistribution of food, which became mandatory by Regulation (EU) No. 2021/382 amending Regulation (EC) No. 852/2004, are now also taken into account.

The decision tree has been revised, the importance of validation procedures in the context of HACCP-based procedures has been underlined, and the Annex III on the subject of auditing GHP and HACCP-based procedures has been redrafted. Types of audits, preparation and conduct of an FSMS audit, requirements for the audit report, the procedure for initiating follow-up measures and the further procedure depending on the audit result are also explained.

In addition to numerous practical templates such as an audit plan template or a checklist to support HACCP audits, a questionnaire addressed to employees with indicators to assess the food safety culture and the example of a checklist for competent authorities on the same topic are also provided. The Commission Notice 2022/C 355/01 on the implementation of food safety management systems covering Good Hygiene Practices and procedures based on the HACCP principles, including the facilitation / flexibility of the implementation in certain food businesses is available free of charge at:  https://eur-lex.europa.eu/.

Would you like to know more?

Find more information at our product portfolio food safety.

Source: European Commission Note

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Mr. Wolfgang Leger-Hillebrand

Executive Vice President Sector Management Food Safety

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Ms. Elisabeth Voltmer

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