HACCP / ISO 22000

According to the Law of Ukraine “On the Basic Principles and Requirements for Food Safety and Quality”, market operators are required to develop, implement, and maintain permanent procedures based on the principles of the Hazard Analysis and Critical Control Points system (HACCP).

The active HACCP procedures may be developed based on the requirements set out in Order No. 590 of the Ministry of Agrarian Policy and Food of Ukraine dated October 1, 2012, entitled “Requirements for the Development, Implementation, and Application of Permanent Procedures Based on the Principles of the Food Safety Management System (HACCP)”. Compliance with this Order is sufficient to meet legislative requirements.

The HACCP system is the core concept on which all internationally recognized food safety management programs are built.

The HACCP system (Hazard Analysis and Critical Control Points) involves the identification and assessment of potential hazards to food products in order to establish proactive control procedures and reduce risk. It is essential for detecting and preventing hazards during food production. Instead of controlling food safety risks only in the final product, the HACCP plan involves rigorous monitoring of each stage of the production process to prevent contamination hazards from arising.

The scope of HACCP is not limited to food manufacturers only—it must also be developed and implemented by all market operators involved in the storage and distribution of food products, including supermarkets, retail outlets, restaurant chains, fast food services, hotels, and others.

For food industry operators, the HACCP system helps minimize risks associated with product safety, ensures public health protection, and maintains the company’s reputation.

Although HACCP certification is not legally required, having a certified system and a valid certificate significantly increases trust among foreign partners, facilitates market access for exports, and provides a competitive advantage when participating in tenders.

Due to its proven effectiveness in preventing contamination risks, the HACCP concept has become a key foundation for the development of several internationally recognized food safety standards, including:

• ISO 22000 – Food safety management systems – Requirements for any organization in the food chain; developed by the International Organization for Standardization (ISO);
• BRC (British Retail Consortium Global Standard) – the UK standard for retail trade;
• IFS (International Food Standard) – an international standard for food retailers;
• Dutch HACCP – the Netherlands’ standard for HACCP implementation;
• FSSC 22000 – a standard for specific categories of food producers that combines ISO 22000 and PAS 220 requirements, adopted by the Global Food Safety Initiative (GFSI).

Who Needs HACCP?

The following food business operators are required to gradually implement the HACCP system:

• Producers of ingredients;
• Manufacturers and suppliers of food products, including: dietary supplements, food for special medical purposes, weight-control food products, baby food;
• Wholesale and retail food businesses;
• Catering establishments;
• Organizations providing food transportation, storage, and distribution services.

The requirement to develop and implement a HACCP system does not apply to food business operators engaged in primary production, or those involved in related activities, including:

• growing, breeding, and/or rearing of primary products,
• harvesting, milking, and raising or keeping of animals before slaughter,
• hunting, fishing, and gathering of wild plants.

These activities remain outside the HACCP obligation scope, although general food safety principles still apply.

HACCP Principles

The HACCP concept is based on 7 principles that guide how to establish, implement, and manage HACCP in food production. The principles focus on identifying, monitoring, and controlling hazards at critical control points (CCPs) throughout the production chain:

1. Conduct a hazard analysis to identify potential hazards.
2. Determine the critical control points (CCPs) in the production process.
3. Establish critical limits for the control measures associated with each identified CCP.
4. Establish a monitoring system for controlling CCPs.
5. Establish corrective actions to be taken when monitoring indicates that a specific CCP is not under control.
6. Establish verification procedures to confirm that the HACCP system is functioning effectively.
7. Establish documentation and record-keeping procedures to demonstrate the application of these principles.

The full responsibility for implementing the HACCP system and ensuring the proper application of its procedures rests with the market operator.

The HACCP system is subject to official inspections carried out by the State Service of Ukraine on Food Safety and Consumer Protection (SSUFSCP). Therefore, it is not sufficient to merely develop documentation—the system must be effectively implemented and operational at every stage of food production.

The compliance check for HACCP implementation is conducted in the form of an audit, and market operators must provide the competent authority with evidence of compliance with the established requirements. Such evidence includes documentation confirming the existence of developed procedures and the application of food safety control and contamination prevention measures at the facility.

Market operators are required to retain HACCP documentation for a legally prescribed period.

Failure to fulfill the legal obligation to implement permanent procedures based on the principles of HACCP at the facility may result in fines imposed on the market operator.

Our Services

We professionally provide regulatory and legalization services for dietary supplements, baby food, food for special medical purposes, and weight control products. Our team possesses the required knowledge, experience, and skills, and our specialists are fluent in English.

We offer:

• Evaluation of product composition with in-depth analysis of its formulation and assessment of compliance with legislation and relevant category;
• Review or development of labeling and instructions for use (leaflet);
• Arrangement of laboratory testing to verify compliance with safety requirements and obtain a product safety report;
• Preparation and submission of notification for placing on the market dietary supplements, baby food, food for special medical purposes, and weight-control products;
• Development and implementation of HACCP / ISO 22000 systems;
• Legal and consulting support for manufacturers and importers.