HACCP Requirements 2026-2027: Codex, FSSC 22000 v7 and Auditors

What changes for the HACCP plan in 2026 and 2027?

The method does not; everything around it does. The seven principles and twelve steps of the Codex remain the reference, but FSSC 22000 prerequisite programmes, the transition calendar and auditors’ expectations are all shifting around the plan.

The FSSC dates come from the Foundation FSSC Version 7 FAQ, the ISO 22000 dates from the ISO/DIS 22000 project page, and the Codex history (adopted in 1969, revised in 1997, 2003, 2020 and 2022) from the official FAO/WHO edition of the text.

What does the 2020 Codex revision change in the way a plan is read?

It makes you justify every classification. The text separates good hygiene practices from the HACCP system, defines the significant hazard and allows an intermediate level between basic hygiene and the CCP.

On its page on control of operation, the FAO toolbox notes that “certain critical activities or processing steps may require greater attention”. The official text calls them “GHPs that require greater attention”: a fish storage temperature, water chlorination or a label check, for example, depending on the site’s own analysis. They are monitored against defined criteria without being CCPs. ISO 22000 and FSSC 22000 call a similar level of control an OPRP (operational prerequisite programme); BRCGS requires the adequacy of the prerequisite programmes that control a specific hazard to be validated (2.7.4).

Three other points weigh in an audit:

• the significant hazard: only a hazard that is reasonably likely to occur at an unacceptable level without control calls for a CCP; an unranked list of hazards is no longer enough;
• validation before application: according to step 11 of the toolbox, the plan must be validated before it is implemented, then reviewed periodically and whenever changes occur;
• the decision tree: a useful tool, not an obligation; its result must stay consistent with the hazard analysis.

In our diagnostics, we still see plans written before 2020 in which every step is a CCP, for want of an intermediate level. Reworking them starts with the hazard analysis, not with the CCP table.

What do FSSC 22000 Version 7 and ISO 22002-100:2025 change?

The prerequisite programme base, and therefore the foundation of the hazard analysis. The FSSC 22000 Scheme Version 7 requires ISO 22002-100:2025, common to all sectors, and the sector part for the activity, in place of the former ISO/TS 22002-x technical specifications. According to the Foundation, these texts are now international standards.

For a HACCP plan, this means four tasks:

1. redo the table that links each PRP to the hazards it controls, with the clauses of the new standards;
2. check that the PRPs controlling a significant hazard are correctly classified, and validated, as OPRPs;
3. confirm the number of HACCP studies, which the FAQ defines as the hazard analysis for a family of products, processes or services with similar hazards, and which feeds into the audit duration;
4. prepare evidence for the additional requirements that touch the plan, including the testing of parameters critical to food safety, performed in accordance with the applicable requirements of ISO/IEC 17025 (2.5.1).

The changes are detailed in our article on FSSC 22000 Version 7 changes. On the ISO 22000 side, the revision has no date: the current mapping between Codex steps and ISO 22000:2018 clauses remains the one on our ISO 22000 certification page, which also follows the progress of the draft.

What will auditors and inspectors check in 2027?

Evidence that the plan works, more than the plan itself. BRCGS Food Safety Issue 9 makes its Section 2 a fundamental requirement, IFS Food Version 8 classes CCP monitoring as a KO requirement, and the Moroccan sanitary inspectorate of ONSSA (Office National de Sécurité Sanitaire des Produits Alimentaires) checks that the conditions which led to approval are still met. Since Order 2010-25, published in the Official Bulletin (Bulletin officiel) of 15 January 2026, these regular visits may be carried out by an approved body to which ONSSA delegates them; the text of the order is published, in French, on the Ministry of Justice’s Adala portal.

The sources are the BRCGS F904A self-assessment checklist, the official English text of IFS Food Version 8 and Decree 2-10-473 (implementing Law 28-07 on the safety of food products) as published by ONSSA, which our HACCP plan Morocco guide covers article by article.

Is your plan ready for 2027?

• The hazard analysis identifies the significant hazards and justifies each classification as a CCP, an OPRP or a GHP.
  
• The measures that require greater attention have a criterion, monitoring and a record.
  
• Each critical limit has its dated validation file.
  
• The flow diagrams have been verified on the line within the last 12 months, for every shift.
  
• The annual review of the plan has been carried out, with its conclusions and actions.
  
• For FSSC 22000: the PRP table refers to ISO 22002-100:2025 and the sector part, and the number of HACCP studies is confirmed.
  
• No document of the system has been rewritten on the ISO/DIS 22000 draft.
  

To rework the plan step by step, see our article on how to build a HACCP plan.