Accept accredited HACCP for GLOBALG.A.P. aquaculture postharvest

Acceptance of accredited HACCP systems in postharvest units

Producers and quality managers operating aquaculture postharvest units often face confusion regarding acceptable food safety certifications. Under GLOBALG.A.P. Integrated Farm Assurance version 6 Smart and GFS for aquaculture, a postharvest facility does not require a Global Food Safety Initiative benchmarked certification to demonstrate compliance. Principle AQ 28.06.01 explicitly permits producers to hold either a recognised post-farm gate certification or a third-party certified Codex Alimentarius-based HACCP system that is accredited at the time of the audit.

This clarification affects primary producers, processing facilities, and compliance leads who manage postharvest units under Option 1 or Option 2 certification models. Certification bodies evaluate compliance during the annual audit and record the specific recognition type directly in the GLOBALG.A.P. IT systems. Consequently, facilities that maintain accredited ISO 22000 or equivalent accredited Codex HACCP certifications fulfill the Major Must requirement without undergoing additional post-farm gate scheme certification.

In addition, companies that operate under Chain of Custody standards experience identical recognition rules for product handling activities. Control point CoC-SC 1.14 specifies that an accredited Codex Alimentarius-based HACCP system satisfies the mandatory food safety requirement for processing and handling sites. This dual alignment ensures consistent standards across primary production facilities, subcontracted processing units, and supply chain operators.

Postharvest food safety pathways and compliance criteria

The normative documents define specific control points and compliance criteria for food safety recognition across handling and supply chain operations:

• Principle AQ 28.06.01: Requires that each postharvest unit maintains a compliant food safety system through a GFSI-recognized post-farm gate standard or an accredited third-party Codex Alimentarius-based HACCP system.
• Control point CoC-SC 1.14: Mandates that companies handling processed crops, aquaculture products, or post-slaughter livestock hold a GFSI-recognized scheme, an accredited third-party Codex Alimentarius-based HACCP system, or a GLOBALG.A.P. recognized food safety scheme.
• Section 4.8 d: Allows Quality Management Systems to accept subcontracted postharvest handling units that hold recognized post-farm gate food safety certification or existing GLOBALG.A.P. certificates without duplicating full internal food safety audits.
• Principle AQ 28.01.07: Establishes that high-risk postharvest subcontractors must be audited annually within the producer certification or maintain valid Chain of Custody or Integrated Farm Assurance certification.

Subcontractor risk classification and audit obligations

Postharvest management requires systematic identification and evaluation of all subcontracted service providers. Principle AQ 28.01.06 classifies subcontractors based on the risk of misidentification, substitution, or dilution of certified products. Subcontractors engaging in processing, repacking, relabeling, or handling unpacked bulk products are categorized as high-risk operations.

High-risk subcontractors must be audited annually by an approved certification body or maintain independent certification under Integrated Farm Assurance or Chain of Custody standards. Where a subcontracted postharvest handling unit holds an accredited post-farm gate food safety certification or Chain of Custody certification, Quality Management System auditors focus primarily on verifying product segregation, traceability, and postharvest treatments. This approach eliminates redundant auditing while preserving complete product integrity throughout the supply chain.

Furthermore, Principle AQ 05.01 requires producers to verify that all outsourced tasks comply with the relevant principles and criteria of the standard. Based on the subcontractor services, an approved certification body may assess the subcontractor directly or perform a physical assessment. When a subcontractor receives a direct assessment, the certification body issues a letter of conformance specifying the assessment date, auditor name, subcontractor details, and assessed principles and criteria.

What to do now

• Audit system verification: Review the current accreditation status of your third-party Codex Alimentarius-based HACCP or ISO 22000 certificate to confirm it is active and issued by an accredited certification body.
• Subcontractor list review: Update the register of subcontracted postharvest handling units and classify each entity as high-risk or low-risk in accordance with Principle AQ 28.01.06.
• Certificate scope check: Verify that supplier and subcontractor certificates cover the exact postharvest handling activities and species registered in the GLOBALG.A.P. IT systems.
• Internal QMS audit alignment: Adjust internal QMS audit checklists to ensure segregation and traceability are evaluated for certified subcontractors rather than repeating full food safety audits.

Reference documents

• GLOBALG.A.P. Integrated Farm Assurance Smart/GFS – principles and criteria for aquaculture, v6.0_Mar23, Section AQ 28, Principle AQ 05.01, Principle AQ 28.01.06, Principle AQ 28.01.07, Principle AQ 28.06.01
• GLOBALG.A.P. Chain of Custody – control points and compliance criteria, v6.1_Nov22, Control point CoC-SC 1.14
• GLOBALG.A.P. general regulations – Rules for Quality Management System, v6.0_Sep22, Section 4.8 d