Here’s what I’ve noticed after helping companies transition from the 2005 version to ISO 22000:2018: most teams aren’t confused about food safety—they’re confused about what actually changed. They’re unsure which documents need updates, which processes must be restructured, and how these new requirements affect certification.
My background is rooted in supporting food manufacturers, distributors, and food-service companies through ISO 22000 implementation, internal audits, and certification. Over the years, I’ve guided teams through both standards, and I’ve seen firsthand how a clear comparison speeds up the transition and reduces audit findings.
This article walks you through the key differences between ISO 22000:2018 and 2005 in a practical, at-a-glance way. You’ll see what changed, why it matters, and how to update your Food Safety Management System (FSMS) without rebuilding everything from scratch.
Now that we’re aligned, let’s look at what actually shifted in the 2018 revision.
Shift to the High-Level Structure (HLS) – ISO 22000:2018 Structural Changes
If you’ve worked with ISO 9001 or ISO 14001, the layout of the 2018 version will feel familiar. ISO 22000 adopted Annex SL, which means the structure now aligns with other management system standards. This change wasn’t about adding new food-safety requirements—it was about improving consistency.
Why this matters: Teams can integrate ISO systems more easily. Clause numbering is cleaner. Responsibilities are clearer. And documentation becomes much easier to organize.
Pro Tip: Before updating any SOPs, create a simple mapping table that shows where each 2005 requirement sits in the 2018 structure. It prevents duplicated documents and keeps your FSMS tidy.
Common pitfall: I’ve seen companies rewrite everything from zero because they assume “new structure = new system.” That’s unnecessary. The core food-safety fundamentals stayed the same.
A quick example from experience: I once worked with a supplier who kept their old 2005 structure and simply added 2018 documents on top. The result? Two conflicting FSMS architectures. Their certification audit took twice as long because auditors had to navigate both systems. Once we rebuilt the structure following Annex SL, their next audit had zero findings.
Context of the Organization & Risk-Based Thinking – New ISO 22000:2018 Requirements
ISO 22000:2018 brings a more strategic mindset. You’re now expected to understand how your internal and external environment influences your FSMS. This includes industry trends, regulatory expectations, customer pressures, and supply-chain vulnerabilities.
Here’s the important shift: The 2018 version introduces two levels of risk:
Business-level risk — strategic risks that affect your FSMS (e.g., supplier instability, cybersecurity, workforce gaps).
Food-safety hazard risk — operational risks controlled through PRPs, OPRPs, and CCPs.
A lot of teams blur these together and end up documenting hazard risks only.
Pro Tip: Use two separate risk matrices. One for management-level risks, one for food-safety hazards. It keeps everything clean during audits.
Common pitfall: Treating hazard analysis (HACCP-style) as the only risk process. Auditors expect to see how leadership evaluates business risks too.
Stronger Emphasis on Leadership and Accountability – ISO 22000:2018 Leadership Requirements
In the 2005 version, leadership commitment was implied. In the 2018 revision, it’s unmistakable. Top management must actively lead the FSMS, not just approve budgets or sign policies.
What this looks like in practice:
Leadership participates in management reviews.
They set measurable food-safety objectives.
They ensure communication flows across departments.
They demonstrate accountability for system effectiveness.
Pro Tip: Schedule quarterly food-safety briefings where leadership can review KPIs, resources, and risk updates. It creates clear evidence of involvement.
Common pitfall: Relying solely on the Food Safety Team Leader. Certification bodies want to see leadership making decisions—not just receiving reports.
Operational Changes: PRPs, OPRPs & CCPs – Updated Hazard Control Logic in ISO 22000:2018
One of the biggest questions I still get is, “Did the CCP/OPRP classification change?” The answer is yes—but not dramatically. The 2018 version simply refines how you classify control measures.
Here’s the heart of it:
PRPs create the clean, safe environment.
OPRPs manage significant hazards but aren’t CCP-level.
CCPs control hazards where failure would be unacceptable.
The 2018 decision tree is clearer and helps prevent misclassification.
Pro Tip: Use the ISO 22000:2018 decision-making diagram instead of relying on old HACCP templates. The logic is more consistent and reduces audit debates.
Common pitfall: Many sites still classify controls using 2005 logic, which leads to mismatches between risk assessment and monitoring activities.
Updated Documentation & Communication Requirements – ISO 22000:2018 Documented Information
The term “documented information” replaced the old “documents and records.” It sounds simple, but it changes how you manage your FSMS.
What improves: You get more flexibility in format, but control must be tighter. Communication processes also need to be more structured—especially for PRPs, OPRPs, and CCP updates.
Pro Tip: Use electronic document control if possible. It speeds up approvals, version control, and distribution across sites.
Common pitfall: Teams update forms but forget to update supporting documents like flowcharts, work instructions, and monitoring sheets. Auditors always spot inconsistencies.
Enhanced Emergency Preparedness & Traceability – ISO 22000:2018 Operational Updates
ISO 22000:2018 increases the bar on emergency readiness and traceability. You need clearer procedures, better-defined roles, and faster recall capability.
Why this matters: Regulators and certification bodies expect companies to demonstrate real readiness—not just paperwork.
Pro Tip: Run at least one mock recall each year and measure KPIs like traceability speed and communication effectiveness.
Common pitfall: Outdated contact lists or missing recall logs. These are among the most frequent nonconformities I see during audits.
Frequently Asked Questions – ISO 22000:2018 Revision Explained
What’s the biggest difference between ISO 22000:2018 and ISO 22000:2005?
The adoption of Annex SL (High-Level Structure) and the clearer separation between strategic/business risks and food-safety hazard risks.
Do we need to rebuild our FSMS from scratch to transition?
No. Most systems need refinement—not reconstruction. Your hazard analysis, PRPs, and CCPs remain valid but should be aligned with 2018 logic.
How long does the transition typically take?
Most companies complete the transition in 2–6 months, depending on document maturity and audit schedules.
Conclusion – What to Do Next
ISO 22000:2018 introduced important changes, but they’re manageable when you understand what actually shifted. Once you align your structure with Annex SL, strengthen risk documentation, update leadership involvement, and refine your hazard-control decisions, the transition becomes straightforward.
I’ve supported many teams through both versions, and the companies that succeed fastest are the ones that follow a clear, intentional roadmap.
If you want to move quickly, your next step is simple: use a structured transition checklist or update your FSMS using a gap-analysis tool. It keeps the process clean and prevents rework when the audit comes around.
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.
