Hi Everyone,
I have now completed a full comparison on the old ISO 22002-4:2013 with: ISO 22002-100:2025 and ISO 22002-4:2025. I would expect that the new 2025 documents will be included in an updated version of the FSSC 22000 Certification Scheme in the near future given ISO 22002-4:2013 has been withdrawn.
From ISO:
ISO 22002-100:2025 Prerequisite programmes on food safety Part 100: Requirements for the food, feed and packaging supply chain is intended to be used when establishing, implementing and maintaining the PRPs specific to the organization(s) in conjunction with ISO 22000:2018, 8.2.
ISO 22002-100:2025 comprises the common PRPs from the prior sector-specific series ISO 22002-1, ISO 22002-2, ISO 22002-4, ISO 22002-5, ISO 22002-6 and the new ISO 22002-7, to provide a unified understanding of PRPs across sectors and to simplify PRPs for organizations operating in multiple sectors.
Where unique sector-specific PRPs remain, or a new sector is added with unique PRPs, these are provided in the other parts of the ISO 22002 series, which are designed to be used in conjunction with this document.
For Food Packaging Manufacturers, ISO 22002-4:2025 Prerequisite programmes on food safety -
Part 4: Food packaging manufacturing is intended to be used in conjunction with ISO 22000 and ISO 22000-100.
Links to the relevant ISO 22002 documents:
ISO 22002-4:2025 Part 4: Prerequisite programmes on food safety - Food packaging manufacturing
The documents are copyrighted so I can’t post the full comparison but a summary of my notes of the changes from ISO 22002-4:2013 to the requirements of both ISO 22002-100:2025 and ISO 22002-4:2025 is in the pdf attached below.
New 22002 Packaging Comparison.pdf 596.54KB
4 downloads
Key Changes that I have noted:
4.2 Environment - The site/facilities should be located away from external sources of contamination, such as: a) polluted areas … d) areas where waste, either solid or liquid, cannot be removed effectively
Effective measures shall be taken to protect the products and/or mitigate against contamination from the environment
5.4 Storage of food, packaging materials, ingredients and non-food chemicals
A separate, and where required, secure …. storage area … for cleaning materials, chemicals and other hazardous substances.
6 Utilities
Some Rewording regarding quality of utilities
Need for maintenance and service activities for utilities
6.2 Water, ice and steam
Change to establish requirements criteria (microbiological, chemical and physical) for water (including ice and steam)
6.4 Compressed air and other gases
Change from requirements Specifications for microbiological, chemical and physical (solid particulate, water and oil) quality of compressed air and other gases shall be established, where necessary, and should be monitored accordingly.
6.5 Light
Lighting shall support the ability to detect defects or contamination of products and the examination of facilities and equipment for cleanliness.
7 Pest Control Section is generally a lot more prescriptive with the main requirement for an effective pest control programme shall be established, implemented, maintained and documented.
8 Waste, FLW management and recycling
8.1 General
Reworded requirements for a waste management programme … etc.
Documented information of the identification and disposal or destruction of waste and/or food waste shall be retained.
New Section 8.2 Recycling and/or reuse of materials
8.3 Waste containers - Extended requirements
9 Equipment
Considerable rewording of requirements
Additions:
Install and use equipment in accordance with the conditions of use provided by the manufacturer or…
Additional requirements for use and inspection of equipment
Removed Equipment used for irradiation purposes
9.2 Equipment capability
Requirements for design and capability, monitoring and verification
9.3 Maintenance Reworded
Additions: Where there is a potential for direct or indirect contact with the products, lubricants and heat transfer fluids shall be food grade.
Change to: Procedure for releasing maintained equipment for return to production from remove any potential contaminant from machinery and equipment after maintenance work.
10.2 Selection and management of suppliers
Examples of how suppliers are assessed given including audit and third-party certification
11.1 Storage and warehousing Reworded throughout
Additional requirements for control of stacked materials and product
New Section 11.2 Dispatch
Requirements for pallets removed
12 Measures for prevention of contamination
Removed large parts of 4.7.1 General requirements including ‘external product testing’ by an accredited test facility and specific mention of 4.7.2 Microbiological contamination
Rewording for transport of different products and for bulk containers
13 Cleaning and disinfection
13.1 General
Reworded
Programmes need to include:
a) specified areas of the site/facilities;
b) equipment, including transport containers;
c) the working environment.
13.2 Cleaning agents and tools
Need to select and/or authorize the cleaning agents and tools that are fit for purpose.
13.3 Cleaning and disinfection programmes
Rewording Programmes need to be: appropriate to the food safety hazard associated with the product(s), capable….. and not compromise food safety
14.4 Workwear and protective clothing
More extensive requirements Including for workwear to be laundered, for personal lockers and for gloves
14.5 Health status
More specific: Documented procedures for handling illness and injuries shall be established …..
14.8 Visitors and external providers
New requirements for the control of visitors and external providers
Requirement for Product withdrawal procedures removed
15 Product and consumer information
Condensed
Packaging specific compliance requirements in ISO 22002-4:2013 are NOT included in ISO 22002-100 Part 100 or ISO 22002-4:2025
16 Food defence and food fraud
16.1 General
The organization shall implement and maintain measures to protect products from
Addition of b) mislabelling, counterfeiting and tampering; c) and theft.
New requirements for Food Defence in new section 16.2
New Section/requirements 16.3 Food Fraud Prevention
Comments on Allergen Management and Design and Development:
Allergens
Previous requirements in Section 4.7.6 Allergen Management in ISO 22002-4:2013: ‘Where a potential for contamination from food allergens has been identified, controls shall be established, documented and implemented to prevent or control the hazards and to record and label accordingly’ is NOT included as section in ISO 22002-4:2025 or ISO 22002-100
No mention of allergens in ISO 22002-4:2025 Part 4: Prerequisite programmes on food safety - Food packaging manufacturing
ISO 22002-100 Part 100: Requirements for the food, feed and packaging supply chain
Systems shall be in place to detect, prevent, control or minimize contamination and cross-contamination, to an acceptable level relevant to food safety hazard assessment. Contaminants can include allergens, physical, chemical or biological agents.
Note: Allergen management is covered in FSSC 22000 Additional requirements 2.5.6 Management of Allergens (see list of requirements below)
Food Packaging Design and Development
Food Packaging Design and Development was included in PAS 223 Prerequisite Program for Food Packaging:
19.1 General requirements
19.2 Communication and change control
19.3 Design
19.4 Specifications
19.5 Process validation
but not ISO 22002-4:2013, it is expected they are covered by covered by ISO 22002-4 4.14 Food Packaging Information and Customer Communication plus ISO 22000 clauses:
External Communication
Intended Use
Characteristics of End Products
Raw Materials, Ingredients and Product-contact Materials
Validation of Control Measure Combinations
Control of Measuring and Monitoring
Note: Packaging design and development is also covered in FSSC 22000 Additional requirements 2.5.13 Product Design and Development (see below)
For Production of Food Packaging and Packaging Materials (Category I), other Requirements for PRPs to Note for those looking for FSSC 22000 Certification - FSSC 22000 Additional Requirements (currently V6) apply:
2.5.1 Management of Services and Purchased Materials - Note includes Laboratory requirement (All Food Chain Categories)
2.5.2 Product Labelling and Printed Materials (All Food Chain Categories)
2.5.3 Food Defense (All Food Chain Categories)
2.5.4 Food Fraud Mitigation (All Food Chain Categories)
2.5.5 Logo Use (All Food Chain Categories)
2.5.6 Management of Allergens (All Food Chain Categories)
2.5.7 Environmental Monitoring (Food Chain Categories BIII, C, I & K)
2.5.8 Food Safety and Quality Culture (All Food Chain Categories)
2.5.9 Quality Control (All Food Chain Categories)
2.5.10 Transport, Storage and Warehousing (All Food Chain Categories)
2.5.11 Hazard Control and Measures for Preventing Cross-contamination (All excluding FII)
2.5.12 PRP Verification (Food Chain Categories BIII, C, D, G, I & K)
2.5.13 Product Design and Development (Food Chain Categories BIII, C, D, E, F, I & K)
2.5.14 Health Status (Food Chain Category D)
2.5.15 Equipment Management (All excluding FII)
2.5.16 Food Loss and Waste (All excluding I)
2.5.17 Communication Requirements (All Food Chain Categories)
2.5.18 Requirements for Organization with Multi-Site Certification (Food Chain Categories A, E, F & G)
Kind regards,
Tony
