a point. It would be helpful if the EU would recognize compliance with a
GFSI-benchmarked standard as compliance with HACCP, and if the U.S. would recognize it as compliance with HARPC [Hazard Analysis and Risk-Based Preventive
Controls]. This being said, if a business wants to export to the EU, it has to identify
CCPs in its process; if it wants to export to the U.S., it needs to have a risk-based
control plan and employ a Preventive Controls-Qualified Individual.
Apart from process requirements, product requirements apply. These include
quality standards addressing the composition of products (how much cocoa in choc-
olate? are noncocoa fats allowed?), levels of contaminants,
Government regulatory authorities, the
food industry, public welfare organiza-
tions, and scientists should participate
together to promote the global develop-
ment and progress of food safety.
FSM: Do you think the ISO 22000
standard already meets the need for international harmonization? Why or why
SAAT: ISO 22000, especially its
latest version (ISO 22000:2018), is the
ideal standard for international harmo-
nization of food safety management
for businesses. It combines and supple-
ments the core elements of ISO 9001
and HACCP to provide an effective
framework for the development, imple-
mentation, and continual improvement
of a documented food safety manage-
ment system. Furthermore, it has been
following internationally desired objec-
• Strengthen food safety,
• Ensure consumer protection and
strengthen their confidence,
• Encourage cooperation between in-
dustries and governments, and
• Improve cost performance through-
out the food supply chain.
CB: Both ISO 22000 and the Codex
food hygiene standards, guidelines,
and Codes of Practice are widely used.
However, Codex is referenced in the
WTO-SPS agreement, providing Codex
a large and important role in providing
guidance to the WTO and its members.
Thus, Codex standards should be the
basis for international harmonization.
BVDM: ISO 22000 is a food safety
management system. It could contribute to global harmonization insofar as
countries would be willing to accept certification against this standard as proof
of compliance with national process
requirements. Private standards such as
ISO can be used as a tool to deal with
differences in national requirements.
Additionally, private standards may
provide tools to deal with diversity in
public law requirements, but only up to
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