212 | What's New In Food Safety Standards |
Plus: howling for leftovers
Controversial new GFSI auditor requirements
Food fraud requirements in food safety standards
Disappearing tequila
Howling for leftovers
Food fraud news, incidents and horizon scanning + downloadable
This month there’s a lot of chat in the international food safety community about upcoming changes to auditor requirements for GFSI-benchmarked food safety standards. This prompted me to take a look at the new benchmarking requirements to discover if they really are too stringent (short answer: yes).
In this week’s article, ‘What’s new in food safety standards’, you’ll find a summary of the new auditor requirements, with a more detailed breakdown for paying subscribers.
Also in this issue, an overview of food fraud requirements in food safety standards, including some surprising variations, and a food fraud case study with a half-happy ending.
Enjoy!
Karen
P.S. Shoutout to 👏👏Malcolm from the UK 👏👏 for upgrading to a paid subscription. Your financial support keeps this publication thriving.
What’s new in food safety standards
In the past year, new standards have been published, new editions have been delayed, and the GFSI has sparked a furore with its controversial new requirements for auditors. Let’s explore.
New standards: ISO 22002, FSSC 22000 and SQF Edition 10
ISO 22002
In July 2025, the International Standards Organization released a completely updated set of standards in the ISO 22002 series. This series addresses prerequisite programs (PRPs) within the ISO 22000 group of standards for food safety management systems (FSMS).
The new ISO 22002 series redefines how PRPs are specified in food safety management systems and removes duplication across standards for different industry sectors.
Every industry sector used to have a separate standard describing PRPs for elements such as allergen control, hygiene and traceability, each with slightly different language and with significant duplication across sectors.
With the new series, there is now a common shared base for PRPs across food, feed and packaging sectors, with extra requirements for each sector building on the shared framework.
The common framework is found in ISO 22002-100:2025 Common requirements for prerequisite programmes (PRPs) in the food chain, which sets baseline requirements applicable across all sectors.
Each sector also gets a new sector-specific standard, each with its own number, with the series referred to as ISO 22002-X:2025. For example, ISO 22002-1:2025 for food manufacturing, ISO 22002-2:2025 for catering, ISO 22002-4:2025 for food packaging and so on.
There are a number of new requirements introduced to the ISO 22000 family with this update, including food safety culture, food defence, food fraud, biosecurity, sustainability and food waste, strengthened requirements for supplier approvals and a requirement to demonstrate the effectiveness of PRPs.
Overall, the new series represents a great leap forward for the ISO 22000 standards, with a more user-friendly structure, more modern language and better alignment with industry best practice and international regulations.
FSSC 22000
FSSC 22000 is a GFSI-endorsed standard built upon ISO 22000, with extra requirements to meet GFSI benchmarks. It’s no surprise that, with the recent changes to ISO 22000, the next version of FSSC 22000 (Version 7) is expected to include significant changes.
The FSSC has announced Version 7 will be published in the first half of 2026. There will be a 12-month transition period for certification bodies and certified organisations. Until Version 7 is implemented, businesses certified to FSSC 22000 should continue to use the previous ISO 22002-X series standards, not the 2025 versions, says FSSC.
SQF Edition 10
Initially expected in September 2025, SQF Edition 10 has not yet been published due to delays related to GFSI benchmarking. The release date for the new edition has not been revealed yet.
Key anticipated changes include a stronger focus on food safety culture, change management, and environmental monitoring, as well as possible revisions to the scoring system and audit methodology. For now, audits will continue under Edition 9 until further notice from SQFI.
A transition period of at least six months has been promised by SQFI, with audits to Edition 10 expected to commence in the second half of 2026.
New GFSI benchmarking requirements
In December 2024, the GFSI published new benchmarking requirements for food safety management standards and scheme owners. The new requirements will result in more elements being added to GFSI-recognised food safety certification schemes.
Reminder: The Global Food Safety Initiative (GFSI) endorses (“recognises”) food safety certification programs that meet its benchmarking requirements. Examples of GFSI-recognised schemes include SQF, BRCGS, FSSC 22000, and IFS.
Last year’s update to the GFSI’s benchmarking requirements included a lot of new requirements that control how certification bodies must operate, notably with regard to the management of multisite audits and the competencies of their auditors.
The new requirements also include 8 entirely new and 36 strengthened requirements for the contents of standards. By comparison, the previous update (2020) contained just 7 new and 12 strengthened requirements related to the content of standards.
New requirements for the contents of standards
A key new requirement in the 2024 benchmarking document is for change management procedures. There are also many strengthened requirements relating to the principles of hygienic design for buildings and equipment.
New requirements include:
HACCP: new requirements for expertise, knowledge of personnel and reviews/updates.
Food safety culture: new requirements require that food safety plans shall include continuous improvement and structured assessments that measure communication, training and performance over time.
Food fraud and food defence: new requirements for appropriate knowledge and expertise of personnel.
Cleaning and disinfection programmes: new requirements.
Change management: a procedure for change management shall be established, focusing on changes that could impact food safety.
Strengthened requirements include:
HACCP plans: many.
Hygienic design: many.
Food fraud and food defence: now include the need to verify, maintain and review assessments and mitigation plans.
New auditor requirements
The GFSI’s new benchmarking requirements set out new rules for auditor qualifications and training.
Auditors must have training in:
HACCP or Hazard and Risk Assessment (HARA) for their specific industry sector and
A food science degree (specifically a “bioscience degree with a focus on food”) or other relevant degree appropriate to their sector.
There are no grandfather rights for current auditors.
They also require at least two years of full-time industry experience in the relevant sector(s). The experience must be in a food safety function. Auditing does not count towards the two years.
Auditors are to be assessed on at least three food safety audits, including one witness audit for their initial qualification, and must conduct at least 5 on-site audits per year.
Implementation and enforcement dates are not set by the GFSI, but by certification scheme owners and certification bodies.
Get a complete analysis of auditor requirements—plus the precise wording of relevant clauses in the GFSI 2024 benchmarking document—in an exclusive PDF for paying subscribers. Access your download at the end of this email, just above the latest food fraud news.
What you need to do
If you’re a food business:
Changes to GFSI benchmarking requirements do not directly affect food businesses. The benchmarking requirements are for food safety scheme owners.
Follow announcements from your certification program owner (SQF, BRCGS, FSSC) to understand when the new benchmarking requirements will be implemented in their standards.
For example, if you’re certified to SQF, wait until Edition 10 is released. Then begin to update your systems to comply with Edition 10.
If you’re a food safety auditor:
If you perform audits against GFSI-benchmarked standards such as SQF or BRCGS, the new auditor requirements will affect you.
Certification program owners such as SQF, BRCGS, and FSSC are expected to phase in new requirements for auditors by imposing new rules on certification bodies
Certification bodies are allowed a transition period to update their auditor approval processes and review auditor credentials. Requirements are expected to be enforced from 2026.
Auditors should contact the certification body(ies) to learn of exact requirements and enforcement dates.
Download the complete auditor requirements from the end of this email, just above the latest food fraud news (for paying subscribers).
Main source:
GFSI (2024) GFSI BENCHMARKING REQUIREMENTS VERSION 2024, PART II IMPLEMENTATION HANDBOOK. Available online at: https://mygfsi.com/wp-content/uploads/2024/12/Benchmarking_Requirements_v2024_Implementation_Handbook_Part_II.pdf
🍏 Next week: 9 Proven Change Management Strategies For The Food Industry 🍏
GFSI Certification Poll
I read a shocking statistic about food safety non-conformances in A-grade certified facilities the other day. Before I share it with you, I’d love to know what you think.
When compared to a food business that doesn’t have a GFSI certification, do you expect an A-Grade certified business to perform better, worse or the same in a regulatory audit?
Food Fraud Requirements in Food Safety Standards
When it comes to food fraud, every food safety standard has slightly different requirements.
For example, some standards require food businesses to include counterfeiting in their vulnerability assessments, while others don’t; some standards specify that vulnerability assessments must be performed on ingredients, while others state they should be done on products and processes.
Some explicitly require training in food fraud awareness, while others do not.
With recent changes to the way food fraud is handled in ISO 22000, I’ve just republished my cheat sheet that helps me keep track of food fraud requirements in the major food safety standards.
Find my ‘cheat sheet’ comparison table below.
Paying subscribers can download the comparison table in PDF format and grab my 43-page e-book Food Fraud Requirements of Food Safety Standards (2025) - a complete guide to food fraud in food safety management systems standards, including human food, animal feed and packaging materials - from this page.
[If you’re viewing this post as an email, you’ll need to click the table to view the whole thing 👇]
Double brokering leads to disappearing tequila
A food fraud case study
In last week’s issue, I told you that food-waste-diversion crimes are being detected at unprecedented levels in Europe, and described how enforcement actions coordinated by Europol had dismantled 13 organised crime groups in their most recent anti-food-fraud operation.
This week’s case study explores diversion-style crime from a North American perspective. This case doesn’t involve the diversion of waste back into the supply chain, but, like those discovered in Europe, it does involve an organised crime group.
When: November 2024
What: 24,000 bottles of Santo Tequila worth more than $1 million.
How: Criminals used non-existent trucking companies and a process called ‘double-brokering’ to gain access to the goods, ensuring they were never delivered to their intended destination.
Details:
In November 2024, a shipment of premium Santo Tequila left Mexico on its way to a warehouse in Pennsylvania, via Texas. The shipment comprised the entire batch of a special lot of tequila that had taken 3 years to make, especially for the 2024 holiday season.
After crossing the border into Texas, the consignment was moved to two semi trucks and entrusted to a logistics company hired by Santo Spirits to deliver the tequila to its warehouse in Pennsylvania, a 2.5-day drive north.
The logistics company hired a trucking company to make the delivery. It outsourced the job to two other trucking companies through a bidding process called double brokering. Drivers hired by the second companies collected the trailers and drove away with the tequila.
In Pennsylvania, the tequila did not arrive as scheduled, and Santo was told there had been a mechanical problem with a truck. A few days later, the shipment still hadn’t arrived. Santo was told the mechanical problem had been worse than first believed, but the delivery would arrive soon, around 5 days later than scheduled.
GPS tracking provided by the logistics company showed the truck was definitely en route. A few days later, Santo was told the truck’s GPS showed it was near the warehouse in Pennsylvania.
But the truck - and the tequila - never arrived.
Investigators discovered the trucking companies had told the drivers to take the trucks to Los Angeles. The trucking companies were fake businesses, with fake online profiles, phoney letterheads, email addresses and phone numbers, and possibly operated by people outside the USA.
The emails about the mechanical issues were falsehoods, and the GPS tracking had been faked.
The drivers, however, were genuine, hired by the fake trucking companies.
The bigger picture:
This type of cargo theft, involving redirection of goods to other locations by remote operators, has increased by more than 1,200% in four years, according to a cargo theft investigator who assisted with the Santo Tequila case.
The Los Angeles Police Department (LAPD)’s special cargo theft unit says that in such cases, the goods are usually sold online or in stores. A recent ‘bust’ found $4.5 million worth of stolen goods in a warehouse.
The outcome:
Santo Spirits was luckier than most. The LAPD cargo theft unit tracked down one of the drivers, who told them he had been directed to drop the cargo in the San Fernando Valley. One truckload - eleven thousand bottles - of the missing batch were found at a warehouse in southeast Los Angeles two weeks after the heist. The other truckload was never found.
Source:
Alfonsi, S. and Chasan, A. (2025). Two truckloads of Guy Fieri’s tequila vanished last year. It shed light on a growing new crime. [online] CBSnews.com. Available at: https://www.cbsnews.com/news/double-brokering-guy-fieri-tequila-heist-60-minutes/.
🍏 Want more case studies? Check out our Food Safety Knowledge Vault 🍏
Howling for leftovers (just for fun)
Friday is Halloween: Beware the Tupperware-wolf.
Below for paying subscribers:
- GFSI Auditor Requirements Download
- Food fraud news, horizon scanning and incident reports
… including:
📌 A promising method for methanol detection in alcoholic beverages
📌 Food fraud questionnaires (x2)
📌 Unusual frauds: artificial sweetener, used cooking oil, a fake government website and wagyu beef marbling made with white chemicals
📌 Massive oil fraud in Vietnam.