When you look at the most successful food safety systems around the world, they all share the same foundation: Codex HACCP. Whether a facility is aiming for ISO 22000, FSSC 22000, BRCGS, or simply meeting regulatory expectations, Codex remains the blueprint.
Over the years, I’ve supported businesses across manufacturing, distribution, and retail, and one thing has stood out: teams who understand the logic behind Codex HACCP build stronger, more consistent food-safety systems. Not because they never face issues, but because they can trace every control back to a clear principle and requirement.
This article breaks down the Codex HACCP Requirements step by step. You’ll see how each principle works, why it matters, and what auditors expect when reviewing your system. By the end, you’ll have a complete, practical understanding you can apply immediately.
What Is Codex HACCP? — The Global Framework for Food Safety Requirements
Codex HACCP is the internationally recognized approach for identifying, evaluating, and controlling food-safety hazards. It forms the backbone of most regulatory systems and recognized certification schemes, which is why understanding it deeply is essential.
Codex requires two major components:
Prerequisite Programs (PRPs) — foundational hygiene and operational practices.
The 7 HACCP Principles — the step-by-step method to control significant hazards.
PRPs handle general food-safety conditions. HACCP tackles higher-risk, process-specific hazards.
This distinction matters. Without solid PRPs, HACCP becomes unstable. Codex is built so both work hand-in-hand.
Pro Tip: Treat Codex HACCP as a workflow — not a checklist. Each step supports the next.
The Codex Preparatory Steps — Laying the Groundwork Before the 7 Principles
Codex requires several preparatory steps before applying the HACCP principles. These steps build the structure that keeps your plan accurate and aligned with real operations.
1. Assemble the HACCP Team
Bring together people who understand ingredients, equipment, production flow, sanitation, and quality. Different perspectives reduce blind spots.
2. Describe the Product
Define composition, processing methods, packaging, distribution conditions, shelf life, and consumer group. Codex expects clarity and completeness.
3. Identify Intended Use
State how consumers will handle and use the product. This influences hazard severity.
4. Construct the Process Flow Diagram
Map every step clearly, from receiving materials to distribution.
5. On-Site Confirmation
Walk through the facility to verify every detail. This is where most errors are caught early.
Common Mistake: Building a plan at a desk without validating the real process environment.
Principle 1 — Conduct a Hazard Analysis (Codex Requirement)
Codex starts with identifying hazards that must be controlled to produce safe food. This includes biological, chemical, allergenic, and physical hazards.
You’ll evaluate:
The nature of each hazard
How likely it is to occur
The severity of potential harm
Which preventive measures already exist
A strong hazard analysis relies on evidence — scientific data, regulatory standards, historical complaints, supplier information, and industry trends.
Pro Tip: Focus on hazards tied to your specific product and process. That’s what auditors assess.
Common Mistake: Creating long lists of generic hazards without evaluating significance.
Principle 2 — Identify Critical Control Points (CCPs)
After determining significant hazards, the next step is identifying which process steps must be controlled to reduce or eliminate those hazards.
Codex recommends using the CCP Decision Tree to determine if a step qualifies as a CCP. Typical examples include:
Cooking
Cooling
Metal detection
Allergen control steps
pH control in fermentation
Every CCP must have a clear justification. This is key for audit-ready logic.
Pro Tip: PRPs control many hazards. CCPs should be used only where necessary.
Common Mistake: Labeling every important step as a CCP. This creates unnecessary monitoring work and weakens the system.
Principle 3 — Establish Critical Limits for Each CCP
Critical limits are measurable boundaries that separate safe product from unsafe product. Codex requires these limits to be validated using scientific, regulatory, or expert evidence.
Examples include:
Minimum cooking temperature
Maximum pH threshold
Metal detector sensitivity levels
Allergen detection test limits
Critical limits must be:
Measurable
Documented
Justified with evidence
Practical to monitor during operations
Pro Tip: Target values and critical limits are not the same. Only critical limits determine compliance.
Common Mistake: Setting limits based solely on past habits or equipment capability.
Principle 4 — Establish Monitoring Procedures
Monitoring is how you confirm every CCP stays within its critical limits. Codex requires monitoring procedures that are:
Clear
Measurable
Assigned to specific staff
Frequent enough to catch deviations early
Monitoring methods might include:
Time–temperature readings
pH checks
Visual inspections
Automated instrumentation
Monitoring must be recorded in real time, not at the end of a shift.
Pro Tip: Choose monitoring methods that your team can perform consistently during busy hours.
Common Mistake: Using checkmarks instead of actual measured values.
Principle 5 — Establish Corrective Actions
When monitoring shows that a critical limit wasn’t met, corrective actions must be taken immediately.
Codex requires that corrective actions include:
Controlling or holding affected product
Identifying the cause of deviation
Correcting the issue
Preventing recurrence
Documenting the entire event
The response must protect the consumer first, then protect the process.
Pro Tip: Staff should know exactly what to do before a deviation happens.
Common Mistake: Fixing equipment but forgetting to address product disposition.
Principle 6 — Verification of the HACCP System
Verification confirms the HACCP system is functioning as intended. It ensures monitoring, CCP decisions, and corrective actions all align with Codex expectations.
Examples include:
Internal audits
Review of CCP records
Calibration checks
Product testing
Trend analysis
Annual HACCP plan review
Verification is different from monitoring. Monitoring checks individual batches; verification checks the entire system.
Pro Tip: Build verification into your calendar so it becomes routine.
Common Mistake: Treating verification as preparation for external audits instead of ongoing assurance.
Principle 7 — Establish Documentation and Record-Keeping Procedures
Documentation is the final principle because it supports all the others. Codex requires records that prove controls were performed correctly and consistently.
Essential records include:
CCP monitoring logs
Corrective actions
Verification and validation evidence
Calibration
Training
Hazard analysis and CCP decisions
Records must be:
Complete
Legible
Signed
Time-stamped
Organized
Stored for the required retention period
Pro Tip: Build a record-keeping system your team can maintain effortlessly.
Common Mistake: Having a solid system on paper but inconsistent or missing records in practice.
How the 7 Codex Principles Work Together
Codex HACCP is designed as a logical sequence. Each principle builds on the previous one:
This sequence creates a closed, traceable loop that ensures food safety isn’t left to chance.
When implemented correctly, the system becomes predictable, stable, and transparent — exactly what regulators and certification bodies expect.
FAQs — Codex HACCP Requirements
Is Codex HACCP mandatory? It depends on your regulatory environment, but most countries and global certification schemes require HACCP based on Codex.
Can small businesses use Codex HACCP? Yes. Codex is scalable. The complexity of documentation changes, but the principles do not.
How often should a HACCP plan be updated? At least annually, and whenever processes, suppliers, ingredients, equipment, or regulations change.
Conclusion — Building a Strong HACCP System Starts with Codex
Codex HACCP gives you a clear, structured way to control food-safety hazards and demonstrate compliance. When you understand the logic behind each principle, implementation becomes far more practical. It’s easier to explain to your team, easier to apply during daily operations, and far easier to defend during audits.
If you want support refining your HACCP plan, developing templates, or preparing for certification, now is the perfect time to strengthen your foundation.
Melissa Lavaro is a seasoned ISO consultant and an enthusiastic advocate for quality management standards. With a rich experience in conducting audits and providing consultancy services, Melissa specializes in helping organizations implement and adapt to ISO standards. Her passion for quality management is evident in her hands-on approach and deep understanding of the regulatory frameworks. Melissa’s expertise and energetic commitment make her a sought-after consultant, dedicated to elevating organizational compliance and performance through practical, insightful guidance.
