ISO 22002-100:2025 Transition Plan: How to Prepare Your PRPs for a Stress-Free Audit

The publication of ISO 22002-100:2025 sent a clear signal to food chain companies: prerequisite programmes can no longer be managed on autopilot, relying solely on legacy approaches. The new document establishes a unified baseline of general PRP requirements and changes the way organizations must build, maintain, and demonstrate the effectiveness of their food safety systems.

For businesses, this is not a mere renaming of a standard. It is a matter of risk management, operational resilience, and customer trust. If your company works with retail chains, exports, or contract manufacturing, auditors will almost certainly ask how you have organized the transition to the new requirements structure. And when the answer boils down to "we're waiting for official deadlines," it looks like a management pause rather than a controlled position.

In Ekontrol's experience, the strongest teams do the opposite: instead of waiting, they immediately launch a transition plan. This delivers several advantages. First, it reduces the risk of nonconformities during the next audit. Second, the company gains time for a calm process update and staff training without a last-minute rush. Third, for customers and partners, it is a clear marker of a mature management system.

The key change is modular logic. ISO 22002-100 sets out a common framework of requirements, while the sector-specific parts of the series detail the rules for specific segments: manufacturing, packaging, transport and storage, feed, retail, and others. For multi-site companies, this is especially convenient because baseline requirements can be unified without duplication across each business unit.

However, modularity does not mean simplification on paper. On the contrary, it demands a more precise process map and clear boundaries of responsibility. The team must clearly understand where general PRP controls apply, where sector-specific additions are needed, and how compliance is evidenced through records. Without this, the risk of a gap between procedures and actual practice grows.

That is why the transition to ISO 22002-100 should start not with editing templates, but with a process diagnostic. When the company sees the full picture — from incoming raw materials to dispatch — it identifies priorities faster and updates PRPs without placing unnecessary burden on its people.

One of the most important aspects of the current transition is the ISO 22000:2018 requirement for planning of changes (clause 6.3). It explicitly states that changes to the management system shall be planned and controlled. This means the company must have a documented approach to transitioning to the updated PRP requirements, not just a general intention to "update later."

During an audit, this is straightforward: if the standard change is already known to the market, the auditor expects to see a management response. It is not necessary to have a completed transition immediately, but there must be a plan, assigned responsibilities, identified risks, timelines, and criteria for verifying results. The absence of such a plan looks like a gap in change management and therefore creates grounds for observations.

It is important to emphasize here: a documented transition plan is a tool not only for audits. For management, it provides transparency on costs and timelines; for the team, it provides a clear course of action; for customers, it provides confirmation that the supplier is working proactively. It is precisely this practical value that makes clause 6.3 critical in the current wave of updates.

A good transition plan does not need to be complex or overly theoretical. Its purpose is to provide a manageable framework for action. In its basic form, it answers several practical questions: what exactly are we changing, why are we changing it, what are the risks of not changing, what are the implementation steps, who is responsible, what are the timelines, and how will we verify effectiveness.

In Ekontrol projects, we recommend starting with a list of changes organized by process. For example: updating PRPs in the sanitation area, revising pest control requirements, refining temperature regime controls, updating traceability in logistics, reviewing supplier evaluations. For each change, the reason is documented with a reference to the new edition of the requirements.

Next, a risk assessment is formed: what happens if the change is postponed or only partially implemented. This helps prioritize tasks and avoid spending resources on secondary items while critical points remain unaddressed. The plan structure is completed by a control block: which indicators confirm that the change is actually working in operations rather than remaining at the document level.

A practical transition plan must include:

• a list of changes with priorities and deadlines;
• assigned roles and resources for each stage;
• verification criteria that confirm the effectiveness of changes.

Below is a compact structure that works well for both internal management and demonstration during an audit.

One of the reasons transitions fail is diffused responsibility. When "everyone is responsible," in practice nobody is. Therefore, management must appoint a transition project owner for ISO 22002-100 and define the role of each function: quality, production, warehouse, logistics, procurement, HR, and technical services.

The project owner maintains the calendar, priorities, and risk escalation. The quality department is responsible for methodology, document control, and verification. Line managers translate requirements into daily actions on the shop floor. HR and mentors ensure training and adaptation. Procurement and legal review supplier requirements and contract terms. This model eliminates grey areas and makes the transition manageable.

For the audit, this is also a plus. When every participant can clearly explain their role, the system appears mature. The auditor sees that the transition is not reduced to a single quality specialist but is supported by the management team.

A gap analysis is needed to separate critical actions from desirable but non-urgent ones. A three-tier priority model works best. The first tier covers critical nonconformities affecting product safety or traceability. The second tier addresses systemic improvements that reduce the risk of recurring errors. The third tier involves optimizing document formats and secondary processes.

When a company tries to update everything at once, the team quickly loses focus. Overload, delays, and superficial solutions appear. It is far more effective to run short implementation waves: first the critical points, then adjacent processes, then stabilization and verification. This preserves operational rhythm and maintains productivity.

At Ekontrol, we often apply the "one change — one verifiable result" rule. This means each transition step must conclude with a checkable outcome: an updated procedure plus signed-off training, a completed traceability test, a closed internal audit item. This approach makes progress visible to management.

A PRP update never works without people. If a line operator, warehouse worker, or logistics shift does not understand the new requirements, the system remains purely formal. Therefore, training must be concise, practical, and role-specific. It is important to explain not only "what to do" but also "why this is critical for food safety."

The same applies to suppliers. In the food safety chain, a weak link at a partner becomes your risk during the audit and in the market. During the transition to ISO 22002:2025, you need to review supplier selection criteria, contractual requirements, evaluation frequency, and deviation response mechanisms. If an external partner performs critical operations, this cannot be left outside the scope of the plan.

The commercial impact of this area is often underestimated. In reality, stable supplier interactions directly affect complaints, returns, and negotiating position with customers. When a company demonstrates chain control, it appears predictable and reliable.

Before an audit, the company must prepare not just a "folder for the auditor" but a complete evidence chain of the transition. Typically, an auditor looks at the alignment of four layers: management decisions, documented changes, actual execution in operations, and verification results. If even one layer is missing, questions arise about the system's maturity.

Practically, this means you need to have: an approved transition plan, a change matrix with risks and timelines, updated procedures, training records, internal audit results, corrective actions, and evidence of their effectiveness. It is also useful to prepare a brief management progress presentation — it helps quickly give the auditor a holistic picture.

When the evidence base is assembled systematically, the audit proceeds much more smoothly. The team does not waste time in a frantic search for documents, and management can convincingly demonstrate that the transition is controlled and delivering results.

The first mistake is waiting for "final external dates" while doing nothing inside the system. As a result, the company enters an audit without a plan and without verifiable outcomes. The second mistake is limiting the effort to renaming references in documents without actually updating processes. The third is leaving suppliers outside the scope of changes, even though they often represent critical risks.

Another common problem is the absence of regular progress reviews. When the transition has no monthly or quarterly review, small delays accumulate and turn into a large gap before the audit. Therefore, a short but disciplined management rhythm is essential: status, deviations, corrective actions, re-verification.

Avoiding these mistakes comes down to a simple formula: early start, clear responsibilities, risk prioritization, and an evidence-based approach to every step. This reduces uncertainty for the team and makes the transition manageable.

For management, the transition to ISO 22002-100:2025 should not be a "quality department project" but part of operational management. The most practical way to keep the process under control is to immediately define a small set of KPIs that show real progress. Without this, even a good plan quickly loses momentum, and the team reverts to reactive mode.

The first KPI is the percentage of closed changes in critical PRP blocks. It answers the main question: have the points that can directly affect safety, traceability, and production stability been addressed? The second KPI is the proportion of staff who have completed role-specific training and confirmed their understanding of the requirements. The third KPI is the effectiveness of internal audits after changes: the number of recurring nonconformities, the speed of closing corrective actions, and the trend in shift-level incidents.

It is useful to add commercial metrics as well. For example: the number of customer audits passed without critical observations; the speed of new contract approvals; the frequency of additional customer requests for PRP control evidence. When these indicators improve, management gains a clear link between the investment in the transition and business results.

Regarding timelines, it is important to avoid two extremes: an overly optimistic schedule and an indefinitely stretched-out transition. A staged model with control gates works well in practice. The first stage is the gap analysis and approval of the scope of changes. The second is the implementation of critical PRP blocks and training of key roles. The third is stabilization, internal audit, and corrective actions. The fourth is preparing the evidence base and verifying readiness for the external audit. The transition between stages should only occur after pre-defined criteria have been met.

The budget also needs to be planned as a managed cost portfolio, not as a single lump sum "for certification." Typically, it consists of four blocks: methodology and document updates, staff training and engagement, internal audits and corrective actions, and external audit or customer assessment. This structure makes it possible to see exactly where overruns occur and how to correct them without compromising project quality.

A separate recommendation is to have a reserve for unforeseen adjustments. During the transition, dependencies between departments that were not visible at the start are often discovered: for example, a change in logistics procedures affects labeling and warehouse records, which in turn requires updated training for adjacent teams. A small reserve of budget and time allows these issues to be resolved without disrupting the overall schedule.

In Ekontrol projects, we track progress monthly at a short management meeting: KPI status, schedule deviations, root causes, decisions, responsible parties, and the date for re-verification. This rhythm gives management real control and the team clear priorities. Ultimately, the transition to ISO 22002-100 proceeds not as a "one-off campaign before the audit" but as a systematic strengthening of the system that delivers benefits in both operations and sales.

The transition to ISO 22002-100:2025 is not about "updating paperwork" — it is about strengthening the company's operational system. A business that plans changes following the logic of ISO 22000:2018 (clause 6.3) gains greater control, lower audit risks, and a stronger position in customer negotiations.

In market conditions, this provides a real advantage. When a supplier demonstrates a structured transition, partners see management maturity and a readiness for long-term collaboration. This is often the deciding factor when choosing between several companies with a similar product.

If you need a practical transition without halting operations, the Ekontrol team can build a roadmap, conduct a gap analysis, update your PRPs, and prepare the evidence base for the audit. As a result, you gain not just compliance with requirements but a managed system that supports business growth.