If you read Section 2 carefully, it's not actually describing a HACCP, but a full hazard analysis. You will probably not find any control points, but you will have a product flow chart which will identify the hazards in the process. Your pre-requisites and procedures (raw material, logistics/transport and warehouse supplier assessments) should be sufficient to show that these hazards are correctly managed.
You will find a lot of potential hazards along the way, such as temperature control in transit, proper import management, food safety certificates, delays in customs etc. All you need to do is document them all and show that that you have anticipated them and have procedures in place to manage them.