Key SQF 10 Changes and New Requirements.
Note: The SQF Code Edition 10 is still awaiting benchmarking to GFSI. Some requirements may be updated once this review is completed.
Updated Scoring System and Core Clauses
SQF Edition 10 introduces an updated scoring approach that places greater emphasis on core clauses, which are critical to food safety performance. Non-conformances against core clauses receive heavier point deductions (2 points for minor and 7 points for major). Core areas highlighted include management commitment, supplier approval, the food safety plan (HACCP), environmental monitoring, allergen management, sanitation, foreign material control, and CAPA systems. Certification ratings remain based on score ranges: 80–100% certified, 70–79% certified with surveillance, 0-69% Certified with unannounced surveillance (re-certification) and below 0-69% Certification is not achieved (initial certification).
Structural Changes to Food Sector Categories
Some Food Sector Categories (FSC) were reorganized:
- Honey is no longer a standalone FSC and is now grouped under FSC 18 (Food Ingredients).
- Plant-based foods are grouped under FSC 14.
- A new category FSC 19 – Food Additive Manufacturing has been introduced.
Contractual Agreements (Clause 2.3.3)
SQF 10 clarifies expectations for contract manufacturers, storage providers, distributors, and service providers. Agreements must:
- Be documented and approved by both parties.
- Clearly describe products and services provided.
- Include information necessary to ensure food safety requirements are met.
- Be communicated internally and kept current.
Change Management (Clause 2.3.5 – New Requirement)
SQF 10 introduces a formal Change Management requirement to ensure that any change that could affect food safety is evaluated before implementation. Sites must document procedures to assess risks and validate controls when changes occur.
Changes that require review include:
- Product formulations or manufacturing processes
- Ingredients, packaging, labels, or equipment
- Specifications for materials or services
- Modifications to the food safety plan or critical limits
The process must include risk assessment, defined responsibilities, documentation, verification, and communication of the change.
Positive Food Safety Culture
SQF 10 strengthens expectations around food safety culture, requiring management to actively promote and maintain behaviors that support food safety. Sites must document and implement a food safety culture improvement plan, including:
- Communication strategies to engage personnel
- Training for employees and management
- Mechanisms for staff feedback
- Measurement and evaluation of food safety activities
The goal is continuous improvement and employee engagement in food safety practices.
Management Review and System Monitoring
Management oversight requirements emphasize regular review of system performance.
Key activities include:
Monthly management updates
- food safety issues
- CAPA progress
- audit results
- customer complaints
Annual management review
- system changes
- outcome of food safety system tests
- trend analysis
- recalls or enforcement actions
- HACCP updates
- performance metrics and KPIs.
CAPA and Root Cause Analysis
SQF 10 reinforces the need for a robust Corrective and Preventive Action (CAPA) system supported by root cause analysis (RCA). The procedure must address issues identified through:
- deviations from critical limits
- complaints
- audits and inspections
- non-conforming product
- verification failures
- withdrawals or recalls
- regulatory infractions
- negative trends in the food safety system
The CAPA process must include corrections, root cause investigation, corrective and preventive actions, verification of effectiveness, and communication of outcomes to management.
The timeline to close Corrective Action Reports (CAR) has also been extended to 40 days.
Food Legislation Compliance (Clause 2.4.1)
Sites must ensure that finished products comply with:
- applicable food safety laws in the country of manufacture
- regulations in the intended market of sale
- customer and company requirements
Compliance must include legal requirements related to sanitation, residue limits, packaging, product identity, net weights, nutritional labeling, allergens, additives, and other regulatory criteria.
Environmental Monitoring Program (EMP)
Environmental monitoring is emphasized as a mandatory, risk-based program. The EMP must:
- be linked to the HACCP hazard analysis
- identify relevant pathogens or indicators
- define sampling frequency and locations
- require CAPA when results exceed limits
- be reviewed annually or when trends or food safety concerns arise.
