The New PRP Foundation: What ISO 22002-100:2025 Means for the Food Industry

In September 2025, industry publications directly called ISO 22002-100:2025 a "new foundation" for food safety. And that is an accurate description. For businesses, the change goes beyond a new document number. It is about rethinking how prerequisite programs are built, how they interact across sectors, and how they are verified during audits.

Previously, many companies worked with separate sector-specific documents in which similar requirements were repeated in different wording. This led to systems overloaded with duplicates, while audit outcomes depended on how formulations were interpreted. ISO 22002-100:2025 introduces a shared PRP framework that aligns the foundation for food, feed, and packaging segments. For management, this means clearer control logic; for teams — fewer contradictions in documents; for clients — greater predictability.

In Ekontrol projects, we view this change as an opportunity to "fix the foundation" rather than simply update references in procedures. If the transition is done right, the company gains two benefits at once: a stronger audit position and better operational discipline.

The full revision of the ISO 22002 series in July 2025 was a response to the new reality of the supply chain. The industry faces risks that were previously considered secondary: raw material instability due to climate change, more complex supply schemes, rapid changes in packaging and distribution channels, and higher expectations for traceability. The old document structure was no longer sufficient for consistently managing these challenges.

The update gave the market a clearer architecture: the base document ISO 22002-100 plus synchronized sector-specific parts. From a business perspective, this means requirements have become closer to practice. A company can build its system from a shared core and add specifics only where they are truly needed.

It is also important that the change shapes the expectations of clients and auditors. Even if strict transition deadlines depend on specific schemes, the market is already evaluating whether a company has an adaptation plan. For the commercial function, this is critical: the absence of a plan is increasingly perceived as a supplier risk.

The idea behind the shared PRP framework is simple: common hygiene, allergen, and traceability principles are described once in a shared module rather than being duplicated in each sector-specific part. This reduces documentation chaos and makes it easier to scale the system, especially when a company operates across multiple business lines.

In practice, this approach delivers a tangible effect on staff training. The foundational principles are the same for all departments, making it easier for teams to understand "why" and "how" requirements work together. Differences remain only in specialized blocks that depend on the type of operation. As a result, onboarding time for new employees is reduced and the risk of errors during shift handovers decreases.

The advantage for audits is also evident. When a system is built from a shared core, it is easier for the auditor to trace the control logic across all stages of the chain. And for the company, this means less time spent on explanations and fewer findings related to contradictions between documents.

The new structure of the ISO 22002 series gives industries clearer boundaries of responsibility. Manufacturing gains a focus on technical process stability and condition control. Logistics and warehousing — on handover control, product condition, and traceability. Retail and wholesale receive a more precise requirement profile that reflects the specifics of the final links before the consumer.

For multi-channel businesses, this means a need for integrated management. The model where each department "lives in its own system" no longer works. The strongest results come from a unified process and risk matrix where it is clearly visible: where shared PRPs apply, where sector-specific additions are needed, and who is responsible for what.

In commercial terms, this directly impacts the quality of client collaboration. The more transparently a company demonstrates control over all links, the fewer additional inspections are required and the faster contracts are agreed upon.

Below is a practical matrix that is useful at the start of the transition and during internal audits.

The updated ISO 22002 series reflects what has already become routine for the market. Climate fluctuations are changing the quality and stability of raw materials. Fraud risks are increasing due to longer and more complex supply chains. Digitalization opens new control tools but simultaneously demands new data discipline.

If PRPs are not updated to address these challenges, a company begins falling behind the market even without any obvious incidents. Problems accumulate silently: more deviations, longer root cause investigations, more difficult client communications. And during an audit, this manifests as a weak ability of the system to prevent risks.

Therefore, the transition to ISO 22002-100 should be used as a moment of modernization. It is an opportunity to reassess where the company can strengthen traceability, automate critical records, improve supplier management, and make risk control more proactive.

For enterprises that already hold ISO 22000 or operate within the FSSC 22000 framework, the worst strategy is to delay preparation. The best approach is to launch a managed transition in stages. The first step is to formally document management's decision to begin adapting to the new series. The second is to conduct a gap analysis and identify critical areas. The third is to approve a roadmap with assigned responsibilities, deadlines, and result control.

In parallel, companies should update the reference base in internal documents, review training programs, adapt internal audit checklists, and verify that supplier requirements are aligned. These actions do not require halting production if they are planned in waves.

In Ekontrol's practice, this model helps avoid last-minute scrambles before an audit. The company gradually brings its system up to the new requirements and has time to verify that changes actually work in daily processes.

To make the transition manageable, it is worth starting with three steps:

• formally approve the change plan at the management level;
• update the requirements matrix and internal audit checklists;
• conduct brief role-based training for critical functions.

A useful gap analysis is not limited to comparing standard clauses with procedure names. Its purpose is to identify where the system loses control in real operations. Therefore, the review must include documents, records, on-site observations, and brief interviews with responsible personnel.

As a result, the areas of change need to be divided into three levels. Critical: those affecting safety and traceability. Important: those affecting process stability and control repeatability. Supporting: those improving convenience and speed of system operation. This classification prevents resource dispersion and enables faster achievement of a controlled state.

When a gap analysis is done correctly, the team receives not a "long list of findings" but a roadmap with priorities. This is exactly what provides predictability in terms of timelines, budget, and audit outcomes.

Transitions most often fail not because of the complexity of requirements but because of poor work organization. To avoid this, changes should be implemented in short sprints. First, the critical PRP blocks and roles with the greatest risk impact. Then, adjacent processes. After each sprint — verification and corrective actions.

This approach provides three practical advantages. First, the team does not lose focus because it works with a limited scope of tasks. Second, management sees real progress rather than a "general sense of movement." Third, production does not stop because changes are integrated into the working rhythm.

At Ekontrol, we typically add a brief communication block to each sprint: what has changed, why it matters, and what actions are mandatory from the next date. This reduces team resistance and increases execution discipline.

For a transition to be manageable, management needs simple and regular metrics. A basic set of KPIs may include: the share of closed critical changes, the percentage of staff with confirmed training, the speed of corrective action closure, the trend of recurring nonconformities, and the number of client or external inspections without critical findings.

It is also worth tracking the budget by blocks: methodology and documentation, training, internal reviews, and external assessment. This structure helps identify where cost overruns occur and enables timely resource reallocation.

Practice shows that even a brief monthly KPI meeting significantly improves transition effectiveness. The team sees priorities, management makes quick decisions, and audit readiness is built gradually without last-minute stress.

Even a strong transition plan can stall if a company underestimates three practical bottlenecks: document quality, actual human behavior, and supplier control. In most failed transitions, the problem is not that the team "didn't know the requirements." The problem is that the requirements remained isolated from everyday operational reality.

The first bottleneck is documentation. Companies often quickly update standard names, but the procedure logic remains the same. For example, a document includes a monitoring requirement but does not define who verifies the records and when. Or there is a deviation response procedure but no clear escalation criteria for when a situation is considered critical. As a result, the system looks complete but does not function as a unified mechanism.

To avoid this, a cascading document review is needed. First, the level of policies and key procedures. Then, work instructions at specific areas. Next, record forms, checklists, logs, and electronic templates. At each level, there must be an answer to a simple question: does the document help manage risk here and now? If the answer is unclear, the document needs to be changed rather than kept "for the archive."

The second bottleneck is people. Transitions to new PRP requirements fail when staff have formally "completed training" but cannot explain their actions in a real scenario. An auditor sees this immediately: an employee can name a term but does not understand how to act during a deviation, where to record the event, whom to notify, or how to confirm the corrective action. This is precisely why training must be role-based and scenario-driven.

A role-based approach means different programs for different functions. Line staff work with specific control actions during their shift. Shift supervisors practice escalation, decision-making, and root cause analysis. The quality department trains on verification and action effectiveness assessment. Procurement and logistics focus on controlling requirements for external partners. When training is broken down by role, the system stops being "theoretical" and starts functioning on the shop floor.

The third bottleneck is suppliers. Under the ISO 22002-100 model, the supply chain is treated as a single risk zone rather than "external territory." If a partner performs a critical operation, their weak point automatically becomes your risk — in both certification and reputation. Therefore, the transition must include a review of supplier evaluation criteria, contractual requirements, inspection frequency, and rapid response mechanisms.

In practice, it is useful to classify suppliers by their level of impact on safety: high, medium, and baseline risk. For high risk, enhanced measures are needed: more frequent assessments, clear record-keeping requirements, periodic on-site visits or remote audits, and verification of corrective actions within specified timeframes. For medium risk — planned monitoring. For baseline — a simplified model. This approach balances safety and costs.

Special attention should also be paid to digital discipline. Many teams already maintain some records in electronic systems but do not always have rules for version control, access rights, and data entry accuracy. During an audit, this is no less important than paper logs. If data cannot be traced or its integrity cannot be confirmed, questions arise about system reliability.

In Ekontrol's service practice, we apply a simple principle: every document change must have an owner, an effective date, a brief explanation, and a follow-up review within 2–4 weeks. This eliminates the classic problem where a new revision is formally approved but the team continues working with the old template. Regular verification of actual document usage delivers a rapid effect on process stability.

When these three bottlenecks — documents, people, and suppliers — are integrated into a single management model, the transition to ISO 22002-100 ceases to be a project "for the audit." It becomes a tool for operational reliability. The company responds to deviations faster, spends less on repeated corrections, has a stronger negotiating position with clients, and passes external inspections with greater confidence. This is the practical purpose of the new PRP foundation.

ISO 22002-100:2025 sets a new maturity standard for PRP systems. Companies that begin the transition early and in a managed way gain more than just formal compliance. They build a system that better withstands market risks, passes audits faster, and strengthens client trust.

For Ukrainian businesses, this is especially important in conditions of high competition for contracts and the demanding nature of international supply chains. A clear position on transitioning to the new PRP foundation already influences how a company is perceived as a reliable partner.

The Ekontrol team helps navigate this path practically: from diagnostics and transition planning to implementation, training, and building the evidence base for audit. As a result, you receive not just an "updated system" but a managed instrument for business growth.