FSSC 22000 Version 7: Why ISO 22002-100:2025 Changes Your PRP Structure

If you manufacture food under FSSC 22000 Version 7, one of the most important changes is also one of the easiest to misunderstand.

Do you implement ISO 22002-100:2025?

Or do you continue using the food manufacturing standard, ISO 22002-1:2025?

For a food manufacturer, the answer is: both.

That single point explains one of the biggest structural changes introduced through the new ISO 22002 series and adopted by FSSC 22000 Version 7.

ISO 22002-100:2025 now contains the prerequisite programme requirements that are common across the food, feed and packaging supply chain. The sector-specific standards then contain additional PRP requirements unique to their respective activities.

Therefore, ISO 22002-1:2025 no longer needs to repeat the complete common PRP framework for food manufacturing.

For applicable food manufacturers under FSSC 22000 V7, the practical architecture becomes:

ISO 22000:2018 + ISO 22002-100:2025 + ISO 22002-1:2025 + applicable FSSC 22000 V7 Additional Requirements.

This article explains why that architecture changed, how Part 100 and Part 1 interact, where organizations can make mistakes during transition, and how food manufacturers can restructure their PRP system without unnecessarily rebuilding everything from zero.

What Is ISO 22002-100:2025?

ISO 22002-100:2025 is the common prerequisite programme standard for organizations operating across the food, feed and packaging supply chain.

Its formal purpose is to establish common requirements for implementing and maintaining prerequisite programmes that help control food safety hazards within a food safety management system.

ISO introduced Part 100 as part of a fundamental restructuring of the ISO 22002 series.

Previously, common PRP requirements appeared repeatedly across different sector-specific documents.

The new architecture separates these shared requirements from requirements that are genuinely sector-specific.

In simple terms:

ISO 22002-100 contains the common foundation. The applicable sector-specific ISO 22002 part adds what is unique to your activity.

This distinction is central to understanding the new PRP structure.

Why Did ISO Create Part 100?

To understand the change, consider how the previous ISO 22002 series worked.

Food manufacturing, catering, packaging manufacturing, transport and storage, feed production and other activities had separate PRP documents.

However, many basic prerequisite programme concepts are relevant across several of these sectors.

This created repeated requirements across sector-specific standards.

The revised ISO 22002 series takes a different approach.

Common PRP requirements from the previous sector-specific series were extracted and consolidated into ISO 22002-100:2025.

The other parts of the ISO 22002 series are then designed to work in conjunction with Part 100 where sector-specific requirements are needed.

This creates a more modular architecture:

• One common PRP foundation
• Sector-specific additions
• Less duplication between standards
• More consistent PRP terminology and structure
• A clearer framework for organizations operating across multiple food-chain sectors

This is why treating ISO 22002-100 as merely another document added to the old structure misses the real change.

The architecture itself has changed.

Does ISO 22002-100 Replace ISO 22002-1?

No.

ISO 22002-100:2025 does not replace the need for ISO 22002-1:2025 where food manufacturing sector-specific requirements apply.

Instead, the revised structure divides the requirements between them.

Part 100 contains common requirements that can apply across multiple food-chain sectors.

Part 1 contains requirements needed specifically for food manufacturing over and above those common requirements.

Foundation FSSC explicitly confirms that a food manufacturer must adhere to the requirements of both ISO 22002-100:2025 and ISO 22002-1:2025.

This distinction matters because an organization implementing only Part 100 could miss applicable food-manufacturing-specific PRPs.

Conversely, treating Part 1 as if it still contains the entire PRP framework could leave the organization overlooking requirements that have moved into Part 100.

The New FSSC 22000 V7 PRP Architecture

For food manufacturers, it is useful to stop thinking of PRPs as one isolated document.

Instead, think of the FSSC 22000 Version 7 food safety system as layers.

This layered model makes the relationship much easier to understand.

ISO 22000 tells the organization that appropriate PRPs need to be established, implemented and maintained.

ISO 22002-100 establishes the common PRP baseline.

ISO 22002-1 supplements that baseline for food manufacturing.

FSSC 22000 then adds scheme-specific requirements.

None of these layers should be reviewed in isolation during an FSSC 22000 V7 transition.

What Happened to the Old ISO/TS 22002-1 Structure?

The removal of “TS” is more than a naming change.

The earlier documents were published as Technical Specifications.

The revised 2025 ISO 22002 documents are International Standards.

More importantly, the content architecture was restructured.

Shared requirements that previously appeared within individual sector documents have been moved into Part 100.

Sector-specific standards can therefore concentrate on requirements that are genuinely unique to their sectors.

This means organizations transitioning from the previous PRP structure should not perform a simplistic clause-number substitution.

A procedure previously mapped to one clause in ISO/TS 22002-1 may now need to be mapped differently across the new structure.

Why This Matters for Your Existing PRP Manual

Many mature food manufacturers already have extensive PRP manuals, procedures, records and operational controls.

The arrival of Part 100 does not automatically mean those controls are obsolete.

The bigger challenge is determining where each existing control now belongs within the revised normative architecture.

For example, an organization may already have established controls covering areas such as:

• Cleaning and sanitation
• Personnel hygiene
• Pest management
• Storage
• Utilities
• Waste handling
• Prevention of contamination
• Equipment-related hygiene
• Facility conditions

The practical transition question is not simply:

“Do we have this procedure?”

It should become:

“Which current requirement does this control address, is the control still adequate, and can we demonstrate its implementation?”

This is why a structured requirement-to-control mapping exercise can be more valuable than rewriting the entire PRP manual.

Why Part 100 Matters Even More for Multi-Sector Organizations

The architecture becomes particularly useful for organizations operating across more than one part of the food supply chain.

Consider an organization that manufactures food but also performs significant storage or distribution activities within its certification scope.

Under a heavily duplicated standards structure, similar common PRP requirements can appear repeatedly across different sector documents.

Part 100 provides a common foundation.

The organization can then identify which sector-specific parts apply to the activities within its scope.

This is one of the reasons ISO describes the revised architecture as useful for organizations operating across multiple sectors.

It can also help auditors evaluate shared PRP controls against a more consistent baseline.

Which ISO 22002 Part Applies to Your FSSC 22000 V7 Scope?

Part 100 is the common foundation, but the applicable sector-specific document depends on the organization’s activities and FSSC food-chain category.

The exact normative documents should always be confirmed against the organization’s FSSC 22000 V7 scope and applicable food-chain category.

A Critical Distinction: Common Does Not Mean Generic

The word “common” can create another misunderstanding.

Common PRPs should not be interpreted as optional, high-level or generic guidance.

ISO 22002-100 specifies requirements.

They form the common operational foundation upon which sector-specific PRPs are added.

For an FSSC 22000 V7 organization within an applicable scope, these requirements need to be translated into actual operational controls appropriate to the site.

A dairy processor, frozen-food manufacturer and dry-food facility may all use the same common PRP architecture, but their implementation can differ substantially because their processes, hazards, infrastructure and operating conditions differ.

Standardized requirements do not mean standardized implementation.

Can Requirements in ISO 22002-100 Be Excluded?

ISO 22002-100 recognizes that not every requirement will necessarily apply identically to every organization.

Where an exclusion is made, it needs sufficient justification, and that exclusion must not adversely affect food safety.

This creates an important audit-readiness principle:

“Not applicable” should be a conclusion supported by the organization’s scope and food safety context — not a shortcut for avoiding implementation.

Organizations should therefore document the reasoning behind justified exclusions where appropriate.

What Happens to Food Defense and Food Fraud Under V7?

This is another area where the new PRP architecture affects FSSC implementation.

Some requirements previously addressed separately through FSSC Additional Requirements are now covered within the revised ISO 22002-x series.

As a result, FSSC Version 7 removes or adjusts certain scheme-specific requirements to reduce unnecessary duplication.

However, this does not mean food defense or food fraud has become less important.

Organizations still need effective systems addressing the applicable requirements.

The location of a requirement within the overall framework may have changed even though the operational need remains.

What Does ISO 22002-100 Say About Food Loss and Waste?

Food loss and waste creates another useful example of why organizations need to distinguish ISO PRP requirements from FSSC Additional Requirements.

Foundation FSSC explains that the relevant ISO 22002-100 requirement addresses how food loss and waste is managed, where applicable, so that it does not create contamination risks.

This is different from requiring an organization to implement a complete food-loss-reduction strategy.

FSSC’s own Additional Requirements separately address food loss and waste reduction where applicable.

Version 7 also includes a new packaging-design requirement for organizations involved in designing primary packaging or packaging materials.

This demonstrates why organizations cannot use Part 100 alone as a substitute for reviewing the complete FSSC V7 scheme.

7 Transition Mistakes That Could Create PRP Gaps

1. Treating ISO 22002-100 as a Replacement for ISO 22002-1

For food manufacturing, both standards are required within the applicable FSSC V7 framework.

2. Reading ISO 22002-1 Without Part 100

The revised Part 1 intentionally does not repeat the common requirements now contained in Part 100.

3. Simply Renaming ISO/TS 22002-1 in Existing Documents

The change involves restructuring of requirements, not merely removal of “TS” from the standard name.

4. Creating Two Completely Separate PRP Systems

Part 100 and Part 1 are designed to work together.

Organizations should integrate applicable requirements into one effective operational PRP system rather than creating unnecessary documentation silos.

5. Forgetting the FSSC Additional Requirements

Meeting the ISO 22002 requirements alone does not represent the complete FSSC 22000 V7 scheme.

6. Mapping Documents but Not Operations

An audit does not stop at a procedure.

The organization needs evidence that controls are implemented and effective in the actual workplace.

7. Assuming “Not Applicable” Requires No Evidence

Where exclusions are permitted, organizations should be able to justify why the requirement does not apply without compromising food safety.

How to Perform an ISO 22002-100 Gap Analysis for FSSC 22000 V7

A useful gap analysis should go beyond asking whether a document exists.

Step 1: Confirm the Certification Scope

Start with the activities included in the FSSC certification scope.

The scope determines which sector-specific PRP standards are relevant.

Step 2: Map ISO 22002-100 Requirements

Identify the common PRP requirements applicable to the organization.

Step 3: Add the Sector-Specific Standard

For food manufacturing, overlay the requirements of ISO 22002-1:2025.

Step 4: Add FSSC V7 Additional Requirements

Review the applicable Scheme Part 2 requirements rather than stopping at the ISO standards.

Step 5: Map Existing Controls

Connect every applicable requirement to actual procedures, operational controls, responsibilities and records.

Step 6: Inspect the Physical Site

PRPs are operational by nature.

Walk through the facility and verify whether documented controls reflect actual conditions.

Step 7: Identify Moved Requirements

Pay particular attention to requirements that previously appeared in sector-specific documents but now sit within Part 100.

Step 8: Review Justified Exclusions

Where a requirement is considered not applicable, document the basis and evaluate whether the exclusion could affect food safety.

Step 9: Update Internal Audit Criteria

Internal audit checklists should reference the revised architecture rather than relying on old ISO/TS 22002-1 clause mappings.

Step 10: Test the System Before the Upgrade Audit

Allow enough operating time to generate evidence that revised controls are implemented effectively.

A Better Way to Build Your FSSC V7 PRP Matrix

Instead of maintaining separate checklists that repeat similar information, organizations can build one integrated PRP matrix.

The objective is not to create a larger spreadsheet.

The objective is to create traceability from requirement → operational control → evidence → verification.

That structure can make internal audits, management review and upgrade preparation considerably clearer.

What Will Auditors Be Preparing For?

The FSSC Version 7 upgrade process also requires existing qualified auditors to complete training and successfully pass examinations covering Version 7 requirements.

Importantly, FSSC specifically requires relevant auditor training on ISO 22002-100:2025 and the sector-specific parts applicable to the categories for which the auditor is approved.

This reinforces an important point for certified organizations:

The Part 100 + sector-specific architecture is not a minor editorial change. It forms part of the technical competence required for Version 7 auditing.

When Do FSSC 22000 Version 7 Upgrade Audits Start?

FSSC 22000 Version 7 was released on 1 May 2026.

Audits against Version 6 may continue only until 30 April 2027.

Version 7 upgrade audits must then be conducted between 1 May 2027 and 30 April 2028.

An upgrade audit is a full audit against the Version 7 requirements and takes place during the organization’s next applicable audit within the official upgrade period.

This means organizations have time to transition — but they also need enough time to implement revised PRPs and generate evidence before the audit.

Questions Your Food Safety Team Should Be Able to Answer

Before declaring your FSSC 22000 V7 PRP transition complete, ask your team these questions:

• Which requirements now sit in ISO 22002-100:2025?
• Which additional requirements apply through ISO 22002-1:2025?
• Which FSSC V7 Additional Requirements apply to our category?
• Have we mapped our old PRP controls to the new architecture?
• Are any requirements duplicated unnecessarily in our documentation?
• Have we identified genuine gaps rather than only document-number changes?
• Can operators explain the controls relevant to their work?
• Can we demonstrate implementation with objective evidence?
• Are exclusions justified?
• Have our internal audit criteria been updated?

If the food safety team cannot confidently answer these questions, the transition may still be incomplete even if the documents have already been revised.

How Shark Certification Can Support FSSC 22000 V7 PRP Transition

Shark Certification lists FSSC 22000 among its Food Safety Standards services and provides broader consultancy, auditing and training support.

For organizations moving to the new FSSC V7 PRP architecture, the practical requirement is not simply obtaining copies of the new standards.

The organization needs to understand how its existing food safety controls map across ISO 22002-100:2025, the applicable sector-specific ISO 22002 part and the FSSC 22000 V7 Additional Requirements.

A structured gap assessment can help identify missing requirements, unnecessary duplication, outdated references and operational controls that require improvement before the Version 7 upgrade audit.

Organizations can also use audit services to evaluate implementation readiness and training services to strengthen competence across food safety teams.

Contact Shark Certification to discuss FSSC 22000 Version 7 transition and food safety management system requirements applicable to your organization.

Frequently Asked Questions About ISO 22002-100 and FSSC 22000 V7

What is ISO 22002-100:2025?

ISO 22002-100:2025 specifies common prerequisite programme requirements across the food, feed and packaging supply chain. It provides the common PRP foundation used with applicable sector-specific parts of the ISO 22002 series.

Does FSSC 22000 Version 7 use ISO 22002-100:2025?

Yes. FSSC 22000 Version 7 incorporates the revised ISO 22002-x:2025 series, including ISO 22002-100:2025 and applicable sector-specific standards.

Does ISO 22002-100 replace ISO 22002-1?

No. For applicable food manufacturing operations, ISO 22002-100:2025 provides the common PRP requirements while ISO 22002-1:2025 provides additional requirements specific to food manufacturing. Both apply within the relevant FSSC 22000 V7 framework.

What is the difference between ISO 22002-100 and ISO 22002-1?

ISO 22002-100 contains PRP requirements common across food-chain sectors. ISO 22002-1 contains requirements specifically applicable to food manufacturing over and above the common Part 100 requirements.

Do food manufacturers need both ISO 22002-100 and ISO 22002-1?

Yes. Foundation FSSC explicitly confirms that food manufacturers under the applicable FSSC V7 scope need to adhere to both ISO 22002-100:2025 and ISO 22002-1:2025.

Why was ISO 22002-100 created?

Common PRP requirements were consolidated into one standard to reduce duplication across sector-specific documents, create a more consistent PRP framework and simplify implementation for organizations operating across multiple sectors.

Is ISO 22002-100 only for food manufacturers?

No. It establishes common PRP requirements across the food, feed and packaging supply chain. Relevant sector-specific parts are then used where required.

Which ISO 22002 standard applies to food packaging manufacturing?

Within the relevant FSSC V7 framework, food packaging manufacturing uses ISO 22002-100:2025 together with ISO 22002-4:2025.

Which ISO 22002 standard applies to transport and storage?

The relevant combination is ISO 22002-100:2025 together with ISO 22002-5:2025 for applicable transport and storage activities.

When must organizations upgrade to FSSC 22000 Version 7?

FSSC allows Version 6 audits only until 30 April 2027. Version 7 upgrade audits are conducted from 1 May 2027 through 30 April 2028.

Should companies rewrite their entire PRP manual for FSSC V7?

Not automatically. Organizations should first map existing controls against Part 100, the applicable sector-specific standard and FSSC V7 Additional Requirements. Existing controls may remain effective even when their location within the standards architecture has changed.

What is the biggest mistake when transitioning to the new PRP structure?

One of the most significant risks is treating ISO 22002-100 and the sector-specific ISO 22002 part as alternatives. For food manufacturing, they work together as common and sector-specific layers of the PRP framework.

Conclusion: Stop Thinking “Part 100 or Part 1”

The most important change in the new PRP architecture can be summarized in one sentence:

ISO 22002-100:2025 provides the common PRP foundation; ISO 22002-1:2025 adds the food-manufacturing-specific requirements.

For food manufacturers transitioning to FSSC 22000 Version 7, the two standards should therefore not be treated as competing alternatives.

They are complementary layers of the same prerequisite programme architecture.

This changes how organizations should approach PRP mapping, internal audits, documentation, gap analysis and upgrade preparation.

The strongest transition strategy is not to rewrite every procedure because a new standard has appeared.

It is to understand where the requirements now sit, map them against real operational controls, identify genuine gaps and verify that those controls work in practice.

If your FSSC V7 transition still asks “Part 100 or Part 1?”, the first step is to change the question.

The better question is: “Have we correctly integrated Part 100, our sector-specific PRPs and the FSSC V7 Additional Requirements into one working food safety system?”