Understanding What “Additional Requirements” Really Mean

Many companies get comfortable after implementing ISO 22000 and their PRPs. Then, during certification, the auditor asks about Food Defense or Environmental Monitoring, and everything stops.

Here’s the thing: FSSC 22000 V6 adds a new layer on top of ISO 22000 and ISO/TS 22002. These are called Additional Requirements, and they’re often where businesses lose easy points during audits.

At QSE Academy, we’ve helped hundreds of organizations close these exact gaps. This guide walks you through every Additional Requirement in Version 6 — what it means, how it’s audited, and what you can do to make compliance part of daily life, not a scramble before audits.

What Are the FSSC 22000 V6 Additional Requirements?

If ISO 22000 is the backbone of your Food Safety Management System (FSMS), the Additional Requirements are its nerve system — they connect everything to reality.

These clauses are defined in Part 2 of the FSSC 22000 Scheme and exist because the GFSI benchmark expects tighter control in areas like supplier management, labeling, fraud prevention, and culture.

In short, these aren’t “extras.” They’re mandatory.

Pro Tip: Treat them like ISO 22000 clauses — each one needs documentation, monitoring, and proof of implementation.
Common Mistake: Reusing your old Version 5.1 templates without aligning them with the new clauses in Version 6, especially the culture and sustainability updates.

Management of Services and Purchased Materials (Clause 2.5.1)

You can’t control product safety if your suppliers and contractors aren’t controlled. This clause ensures that external parties — from raw material vendors to pest-control companies — meet your FSMS standards.

You’ll need a structured system for supplier evaluation, approval, and periodic re-assessment.
That means performance tracking, certificates of analysis, and documented actions for poor performers.

Pro Tip: Keep a Supplier Performance Matrix that tracks delivery accuracy, non-conformities, and audit scores. It makes supplier monitoring measurable, not subjective.
Example: One of our clients discovered a flavoring supplier with inconsistent allergen declarations. A proactive re-evaluation saved them from a recall and impressed the certification auditor.

Product Labeling and Allergen Management (Clauses 2.5.2 & 2.5.6)

Labeling errors cause some of the most expensive recalls in the food industry. This clause requires you to validate labels before production, verify them during packaging, and control allergens systematically.

New in Version 6: auditors now expect digital validation systems, label reconciliation, and clear allergen zoning.

Pro Tip: Use color-coded allergen areas and visual label checks at every batch change. Small habits prevent massive problems.
Common Mistake: Assuming label approval at design stage is enough. You must verify it during every production run.

Food Defense (Clause 2.5.3) and Food Fraud Prevention (Clause 2.5.4)

These two are often mixed up — but they serve different purposes.

• Food Defense protects against intentional contamination.
• Food Fraud Prevention protects against economic deception like ingredient substitution or dilution.

Version 6 demands that both are risk-assessed, documented, and regularly reviewed.

Pro Tip: Create a combined Threat & Vulnerability Assessment (TVA) that covers both defense and fraud. It saves time and provides a holistic view.
Example: A spice exporter started testing for adulteration in turmeric powder after a vulnerability review — preventing a fraud-related suspension from their buyer.

Environmental Monitoring Program (Clause 2.5.5)

This clause got much more attention in Version 6, and rightly so. After several global contamination incidents, FSSC wants proof that you’re testing your environment for pathogens or hygiene indicators.

You need a defined plan showing:

• Zones 1 to 4 (from food-contact surfaces to facility perimeters)
• Sampling points
• Frequency and methods
• Data trending and corrective actions

Pro Tip: Test before and after cleaning — that’s how you show your sanitation program actually works.
Common Mistake: Only swabbing after cleaning. Auditors will ask, “How do you know what you cleaned?”

Food Safety and Quality Culture (Clause 2.5.7)

Culture isn’t a buzzword anymore — it’s measurable.
This clause expects you to show that everyone in the company understands their role in food safety and that leadership actively promotes awareness.

You can measure it through employee surveys, toolbox talks, and performance indicators.

Pro Tip: Start small — monthly “food safety moments” or short quizzes can make a big difference.
Example: One packaging company we worked with started a “Hygiene Hero” program where teams competed for spotless zone audits. Morale and compliance went up together.

Equipment Management and Calibration (Clause 2.5.8)

Equipment can’t protect food if it’s not maintained or calibrated.
This clause focuses on preventive maintenance, calibration schedules, and verification.

Pro Tip: Use digital reminders or software-linked logs so calibration and maintenance don’t get forgotten.
Common Mistake: Only calibrating lab instruments. FSSC 22000 V6 requires all devices that impact food safety — from metal detectors to thermometers — to be controlled.

Management of Food Waste and Water Use (Clause 2.5.9)

Version 6 introduced sustainability-related requirements — a reflection of how food safety and environmental responsibility are now connected.

You’ll need documented controls for:

• Waste segregation and disposal
• Rework validation
• Water usage, reuse, and discharge monitoring

Pro Tip: Keep records showing how water reuse is validated for hygiene safety. It demonstrates both sustainability and compliance.
Example: A seafood processor tracked water reuse cycles and reduced water consumption by 20% — without compromising sanitation standards.

Handling of Food Packaging and Allergen-Sensitive Materials (Clause 2.5.10)

Packaging materials come into direct contact with food, which means contamination risks are real.
This clause requires segregation, storage controls, and pre-use verification — especially for reused or multi-layer packaging.

Pro Tip: Inspect packaging visually before filling, and record cleaning or sterilization results for any reusable containers.
Common Mistake: Treating packaging suppliers as secondary vendors. They’re part of your FSMS and must be qualified like ingredient suppliers.

Verification of PRPs and Subcontracted Services (Clause 2.5.11)

Even if you outsource cleaning, transport, or pest control, you’re still responsible for their performance.
This clause ensures PRP effectiveness is verified regularly, whether managed internally or by a third party.

Pro Tip: Include subcontracted services in your internal audit plan. It’s one of the easiest ways to prove control during certification.
Example: A catering company added its pest-control contractor to the internal audit checklist. It uncovered missed inspections before the external audit — avoiding a major nonconformity.

Summary of New and Updated Clauses in FSSC 22000 V6

Clause No.	Topic	Key Change in V6
2.5.1	Management of Services	Stronger supplier performance monitoring
2.5.3	Food Defense	Physical security controls now mandatory
2.5.4	Food Fraud	Testing and annual vulnerability reviews required
2.5.5	Environmental Monitoring	Enhanced microbiological trending and zoning
2.5.7	Food Safety Culture	New clause — measure, communicate, improve
2.5.9	Sustainability	New addition — water and waste management

FAQs — Clarifying FSSC 22000 V6 Additional Requirements

Q1: Are these Additional Requirements optional?
No. They’re mandatory under Part 2 of the FSSC Scheme and audited with the same rigor as ISO 22000 clauses.

Q2: How often should Food Defense and Food Fraud plans be reviewed?
At least annually, or immediately after major changes to suppliers, ingredients, or site security.

Q3: Can I merge environmental monitoring with my existing PRP checklists?
Yes — as long as sampling, results, and corrective actions remain traceable and trendable.

Conclusion — Making FSSC 22000 V6 Work for You

FSSC 22000 V6 isn’t just about ticking boxes.
These Additional Requirements push your FSMS from compliance to resilience.
They make your system stronger, smarter, and more credible to both customers and regulators.

In our experience, the companies that embrace these clauses — instead of fearing them — pass audits with confidence.

At QSE Academy, we’ve designed templates, checklists, and training modules specifically for every V6 clause.
If you want a smoother certification journey: