What is this Agadir juice producer’s starting point?
The starting point is a familiar one: a site approved by ONSSA, a HACCP plan in place, and European customers who now ask for a GFSI-recognised certificate. This is a typical case, built from situations met on assignments; it does not describe an identifiable company.
The site is in the Souss-Massa region, around Agadir in southern Morocco. It takes in fruit from growers in the region, mainly citrus, washes and sorts it, extracts the juice, filters and pasteurises it, and packs it for European retailers and food manufacturers: chilled fresh juices on one side, ambient-stable juices on the other. Headcount varies widely between the season and the off-season.
What the site already has:
- sanitary approval from ONSSA (Office National de Sécurité Sanitaire des Produits Alimentaires, Morocco’s national food safety office), issued under Law 28-07 and its implementing Decree 2-10-473;
- a HACCP plan for each line, reviewed every year;
- customer specifications, with requirements on pesticide residues and microbiology;
- a quality manager, working alone and heavily taken up by customer audits.
What is missing: a management system in the sense of ISO 22000:2018, PRPs formalised according to the 2025 standards, and most of the FSSC additional requirements.
Why FSSC 22000 rather than another scheme?
Because it is the scheme the customers accept and the one that fits the structure of the site. FSSC 22000 is one of the programmes recognised by the GFSI, just like BRCGS and IFS. So the choice is not made on recognition, but on three practical criteria.
Criterion | Question to ask | Answer in this case |
|---|---|---|
Customer acceptance | Does each customer accept FSSC 22000, in writing? | Yes, confirmed by the main customers |
System structure | Does the site want a reusable ISO management system (quality, environment)? | Yes, management plans further ISO certifications later |
Scope | Fresh juices, ambient-stable juices, or both? | Both, on two lines in the same building |
The last criterion is often handled badly. According to Table 1 of the FSSC 22000 v7 scheme and the category descriptions that follow it, processing of perishable plant-based products, fresh juices included, falls under subcategory CII. Production of ambient-stable food, beverages included, falls under subcategory CIV, one division of which covers thermally or pressure processed products: pasteurisation, commercial sterilisation, high-pressure processing. Both apply ISO 22002-100:2025 and ISO 22002-1:2025, but the certificate scope and the auditors’ qualifications differ. Both lines must be described precisely from the gap analysis onwards.
Which gaps does the gap analysis reveal?
The gap analysis reveals findings that recur in this type of site. They concern the system around HACCP more than HACCP itself: laboratories, production environment, suppliers, culture.
Requirement | Situation found | Action taken |
|---|---|---|
2.5.1 Competent laboratory | Residue analyses sent to the cheapest laboratory, with no evidence of competence | Selection on evidence: ISO/IEC 17025 accreditation, proficiency testing |
2.5.1 Specifications | Raw material specifications not reviewed since they were first written | Annual review process, based on legal and customer requirements |
2.5.7 Environmental monitoring | One-off swabs, with no zoning or trend analysis | Risk-based programme, zoning, sampling plan, annual review |
2.5.8 Culture | No objectives, no measurement | Objectives set by management, plan with targets and deadlines, staff survey |
2.5.11 Foreign matter | Sieves and filters in place, but no risk assessment or procedure for their use; glass breakages handled case by case | Risk assessment per line (sieves, filters, detection), procedure for equipment and breakage management |
2.5.12 PRP verification | Hygiene rounds not recorded | Monthly inspections on record, risk-based frequency |
2.5.16 Food loss and waste | Pulp and peel handed over to livestock farmers without control | Policy, measurable objectives, dedicated flow for by-products sent for animal feed |
2.5.17 Communication | Nobody knows the certification body must be told within 3 working days of a recall | Added to the crisis management procedure |
Two other workstreams take up a large part of the project. The first is grower control. The site buys from many farmers in the region; ISO 22000:2018 requires control of purchased products, and requirement 2.5.1 calls for specifications that are reviewed regularly and based on legal and customer requirements. The site therefore sets up a grower assessment, a risk-based residue testing plan and clear rules for accepting or rejecting lots at intake, including for damaged or mouldy fruit, to be removed before extraction.
The second is labelling. Requirement 2.5.2 requires the finished product to comply with the regulations of the country of sale, allergens and customer requirements included. For a European customer, the label therefore follows the rules of the destination market, and any claim, about origin or production method for example, must be backed by traceability and mass balance.
One point deserves particular attention for exporters: European alerts. The European Commission publishes the notifications of the Rapid Alert System for Food and Feed (RASFF). Regular monitoring of the products and hazards in your sector feeds the hazard analysis, the review of the environmental monitoring programme and supplier assessment.
How do you organise the project around the season?
In two phases: works and documentation during the off-season, implementation and evidence during the season. A project that ignores seasonality fails, for lack of time or for lack of evidence.
The FSSC timetable sets its own framework. Audits against v6 are only possible until 30 April 2027. An initial audit whose Stage 2 takes place from 1 May 2027 is a Version 7 audit. This site, which launches its project in late 2026, therefore builds its system directly on v7.
The order chosen:
- Off-season. Gap analysis, mapping, works (separation of the filling area, floors, drains), writing the PRPs to ISO 22002-100:2025 and ISO 22002-1:2025.
- Before the season. Training of the HACCP team, team leaders and internal auditors; preparation of seasonal worker training in Arabic and Darija (Moroccan Arabic).
- During the season. Implementation, pasteurisation and filling records, first environmental monitoring results, full internal audit, management review.
- Mock audit, then Stages 1 and 2 of the certification audit, with Stage 2 scheduled during a production period.
FSSC 22000 v7 frames this choice (Part 3, section 5.1). The certification body must have a process for setting the audit timing that takes seasonal activities into account, so as to audit the site in operation on a representative number of the product lines and activities in scope. The site, for its part, reports local holidays and shutdowns in good time. And the interval between Stage 1 and Stage 2 must not exceed six months, otherwise Stage 1 is repeated: a Stage 1 held too long before the season can therefore be lost.
The budget for this type of project is detailed in our article on FSSC 22000 certification cost in Morocco.
What lessons for other exporters?
The main lesson: certification is won on the shop floor and over time, not in the manual. Exporters in the Meknes region, whether dairies or fruit processors, find the same issues, with hazards specific to their products.
The checkpoints to remember:
For the full path, see our FSSC 22000 Version 7 consultant guide for Morocco. For sites that are already certified, the v6 to v7 upgrade plan details the upgrade.