Expertise

Yes. Under TR CU 021/2011, procedures based on HACCP principles are mandatory for any food producer regardless of floor area. That is not the same as certification to ISO 22000, IFS or BRC — certification is voluntary and is bought for a specific sales channel. The first step is to describe the actual process: flows of raw material, staff and waste, and where zones cross. Then hazard analysis, and critical control points placed where a loss of control can no longer be corrected downstream. The typical mistake in small plants is formal control points and records filled in retroactively before an inspection.

The real question is different: who is your buyer, and what does their contract say. A certificate is bought for a sales channel, not for tidiness. HACCP is a mandatory EAEU requirement. ISO 22000 adds a management system: documentation, internal audits, management review, communication along the supply chain. IFS and BRC are what European retailers and distributors ask for, and they place requirements on the building itself — zoning, foreign body control, validation, food safety culture. That often means capital expenditure. A sensible order is HACCP → ISO 22000 → IFS or BRC.

An inspector compares the document against the plant. Regulation requires implemented procedures, not paperwork, so the gap between what is written and what happens is the most common source of findings. The baseline set: process and flow descriptions, hazard analysis with critical control points, monitoring records, the production control programme, raw material documents and traceability, sanitation procedures, medical checks and training, and a recall procedure. What usually falls apart: traceability, suspiciously even temperature records, no defined action when a critical limit is exceeded, and allergens that are not separated out.

The manufacturer sets the shelf life but must justify it. "The same as our competitor" is not a defence. The justification rests on three sets of data: microbiology, physico-chemistry and sensory. A product can remain safe and already be inedible — all three are needed. Testing is done on product from real equipment in the final packaging, with reports issued by an accredited laboratory. Storage conditions are inseparable from the shelf life, and for frozen products from the whole cold chain. Extending a shelf life is not a recalculation: it requires new testing after the product or packaging changes.

A label is a regulatory document, and the mandatory set of information is defined by the market you sell into: the EAEU and the EU differ. One label for both markets usually does not work. The mandatory frame: product name, ingredients in descending order of weight, allergens emphasised, nutrition declaration, net quantity, shelf life and storage conditions, manufacturer, conditions after opening, batch identification. Expensive mistakes: an allergen hidden inside a compound ingredient; an ingredient list that no longer matches a revised recipe; storage conditions that contradict the shelf-life justification; an unsupported claim on the front of pack. "No added sugar", "source of protein" and "gluten-free" are regulated claims, not marketing.

Blast freezing is about the speed of passing through the crystallisation zone, not about the final temperature. Slow freezing tears the structure of the product, and that cannot be undone later. Parameters are selected for the specific product and portion geometry and confirmed with trial batches, not taken from the equipment datasheet. The cold chain does not end at your warehouse: transfer, transport, goods-in, display cabinet. Temperature control points need realistic limits, monitoring, and a decision on the batch defined in advance for a deviation. Common failures are an overloaded freezer, warm product placed into storage, and undocumented defrosting.