Hygiene, GMP, HACCP, ISO 22000: Mana yang Wajib?

Many food companies treat hygiene, GMP, HACCP, and ISO 22000 as four certification options that can be chosen according to budget. In fact, these four are a staircase. Each step above requires that the one below it is already in place, and each step has a different legal status in Indonesia. This is the part that is often overlooked.

First step: hygiene practices

The foundation is good hygiene practices or Good Hygiene Practices. BSN has established its latest version as SNI CXC 1-1969:2021, an identical adoption of Codex CXC 1-1969 Rev. 2020. What has changed is not just the standard number. The document structure is now divided into two chapters: the first chapter on GHP, and the second chapter on the HACCP system. In the old version, SNI CAC/RCP 1:2011, HACCP was only an annex. This shift emphasizes that GHP is not a warm-up, but rather a prerequisite.

Second step: CPPOB, and this is a permit

GMP in Indonesia is called Good Manufacturing Practices (CPPOB). Its status is not a voluntary certificate. BPOM Regulation Number 22 of 2021 regulates the procedures for issuing CPPOB Implementation Permits and has been in effect since October 7, 2021. The key term is permit, not certificate, so what you are dealing with is business licensing, not quality awards.

Third step: HACCP and its seven principles

HACCP has been adopted in Indonesia since 1998 through SNI 01-4852-1998. It contains seven principles that must be followed in order: hazard identification and preventive actions, establishment of critical control points, establishment of critical limits, monitoring of each critical control point, corrective actions when monitoring shows conditions outside control, verification procedures, and documentation and records.

Principles one to seven can only be implemented if hygiene and CPPOB are already in place. Without that, almost all stages will appear critical, and the HACCP plan turns into a wish list.

Fourth step: management system

ISO 22000:2018 is the second edition, published in June 2018, consisting of 37 pages. This standard uses the same High Level Structure as ISO 9001 and incorporates the HACCP principles along with their implementation steps from Codex. Two things that are rarely mentioned: there is already Amendment 1:2024 regarding changes related to climate action, and its status in ISO is now "to be revised" with a replacement draft currently in progress. Additionally, certification is not a requirement of ISO 22000, and ISO itself does not issue certificates.

FSSC 22000 is not a standalone standard. It is a certification scheme that combines three elements: ISO 22000:2018, basic requirements programs from the ISO 22002-x series, and additional requirements of its own scheme. Version 7 will be released in May 2026 and will use the new ISO 22002-x:2025 series, including ISO 22002-100:2025 as a common basis across the food supply chain.

Deadlines you need to note in your calendar: audits for Version 6 are still allowed until April 30, 2027, and audits for the upgrade to Version 7 will be conducted from May 1, 2027, to April 30, 2028.

A costly misreading

Codex standards are voluntary. FAO and WHO state that Codex texts can only be enforced after being translated into national regulations or legislation. Therefore, what is binding in Indonesia is not Codex, but Government Regulation Number 86 of 2019 concerning Food Safety.

And here is an update that has not made it into many internal documents: PP 86/2019 has been amended by Government Regulation Number 1 of 2026, established and effective from January 5, 2026. If your quality guidelines still refer to PP 86/2019 without including that amendment, your reference is incomplete.

This order of steps is also discussed in the Food Safety Management System class with ISO 22000 and HACCP. If you prefer to listen to the oral explanation, there is a short clip.

Hygiene, GMP, HACCP, ISO 22000: A Ladder That Cannot Be Skipped

First step: hygiene practices

Second step: CPPOB, and this is a permit

Third step: HACCP and its seven principles

Fourth step: management system

A costly misreading

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