TR CU 021/2011 and EU 178/2002: what actually differs
Both documents require the manufacturer to operate a system based on HACCP principles. The differences start where the theory ends: in the depth of traceability, in the procedure for withdrawing product, and in who exactly carries responsibility for the decision.
The problem
A manufacturer entering the EU market from the EAEU usually assumes that the HACCP system already in place will be accepted as it stands. The audit shows otherwise.
What actually differs
| Aspect | TR CU 021/2011 | EU 178/2002 |
|---|---|---|
| Traceability | One step forward and one step back | One step, but with stricter requirements on how fast the data can be extracted |
| Product withdrawal | The competent authorities are notified after the decision | Immediate notification, before the investigation is complete |
| Responsibility | Shared among the parties in the supply chain | Placed directly on the food business operator |
In practice
On a 22,000 m² site, the difference between "one step back" in the two systems is a difference in how warehouse records have to be structured. Under the EAEU rules, the supplier's batch is enough. In the EU, the auditor will ask for a data extract within four hours, and a manual log will not stand up to that.
- Check how long it takes you to reconstruct the history of a batch.
- Check separately who signs the withdrawal decision.
- Document the regulator notification procedure in advance.
Frequently asked questions
Does HACCP have to be implemented from scratch when entering the EU?
No. But the traceability procedures will need to be extended and the allocation of responsibility reviewed.
Is ISO 22000 enough for European retail?
Usually not: retailers ask for IFS Food or BRC, and treat ISO 22000 as a baseline.