GFSI BENCHMARKING REQUIREMENTS

KEY CHANGES
VERSION 2020.1 to
VERSION 2024
 Key Changes to The GFSI Benchmarking Requirements Version 2020 to Version 2024

NEW ELEMENTS

INTRODUCTION
This document provides an overview of key into management systems, highlighting its
updates to Parts I, II, III, and the Glossary of the GFSI vital importance and alignment with Codex
Benchmarking Requirements (BMR). These updates requirements on Food Safety Culture.
are categorised under two main headings: New • Multi-Site Certification Audits: Clearer definitions
Elements and Strengthened Elements. The revision of of "Central Function" have been provided, along
the BMRS requirements was driven by several critical with new and updated definitions for single-site
factors, including: and multi-site certification, improving the overall
understanding and applicability of multi-site
• Alignment with International Standards: Updates certification option.
have been made to align with the Codex General
Principles of Food Hygiene, ensuring consistency Additionally, we have published a BRAND NEW
with global food safety standards. Implementation Handbook designed to provide
• GFSI Benchmarking Improvements: Revisions detailed guidance and clarity on the requirements.
include updated eligibility criteria, streamlined This comprehensive resource outlines key steps,
benchmarking durations, clarified roles and best practices, and examples to ensure a smooth and
responsibilities, clarification on application successful implementation process. Whether you're
process and sanctioning procedures. new to the Benchmarking requirements or looking for
• Food Safety Culture: A stronger focus has been deeper insights, the handbook serves as a practical
placed on integrating "food safety culture" tool to support your efforts.

Part I: The GFSI Benchmarking Process

General updates: Section specific
• Duplications removed, resulting in a more concise Section 1: Eligibility Criteria
document.
• Roles of the GFSI team and Steering Committee • Removed: CPO not governed or owned by public
(Steerco) clarified to resolve decision-making or government entity.
confusion. • Removed: Ten valid certificates required for each
• Grammar and sentence structure improved where scope of recognition.
required. Major revision planned for the next • Amended CB requirement.
iteration. • Removed: 12 month CPO operational requirement.
• Aligned content with actual processes rather than
outdated expectations eg: Section 3 & 6. Section 3: Application Requirements
• Added cross-references to relevant sections where
necessary.
for GFSI Recognition (renamed from
• Incorporated references to Governance Rules, Application Option)
Antitrust statutes, and the Code of Ethical Conduct.
• Section rewritten.

Section 6: Sanctioning
• Section rewritten.

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 Key Changes to The GFSI Benchmarking Requirements Version 2020 to Version 2024

Part II: Requirements for the Governance

of Certification Programmes
General updates:
• Added references to Governance Rules, Antitrust
statutes, and the Code of Ethical Conduct

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 Key Changes to The GFSI Benchmarking Requirements Version 2020 to Version 2024

PART III: Requirements for the Content of Standards

The Codex Alimentarius Guidelines on food Owner shall ensure that the site has knowledge
constitutes the internationally-recognised reference and align their practices to best industry practices
for food business operators and competent authorities and the Codex Alimentarius General Principles of
to oversee food safety. As such, in addition to the Food Hygiene.
following key elements, the Certification Programme

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Hazard and Risk Appropriate knowledge and expertise for the development of
HACCP 1.4.1 Management an effective Hazard and Risk Management System (or HACCP
System system) shall be used.

Hazard and Risk Management System (or HACCP system) shall

Hazard and Risk
be reviewed regularly and updated when there is a significant
HACCP 1.4.2 Management
change that could introduce new hazards and/or control
System
measures.

Food Safety A demonstrable commitment from all personnel to the

FSM 2.1
Culture production and safe handling of food shall be available.

A food safety culture assessment plan shall be established,

implemented and maintained to identify areas of improvement
Food Safety to drive a positive behaviour. This shall include elements
FSM 2.2
Culture consisting of at a minimum: communication, training, feedback
from employees and performance measurement on food safety
related activities.

Appropriate knowledge and expertise for the development and

FSM 7.4 Food Defence maintenance of an effective food defence threat assessment
plan shall be used.

Appropriate knowledge and expertise for the development and

FSM 8.5 Food Fraud maintenance of an effective food fraud assessment plan shall
be used.

Cleaning and disinfection programmes shall be established,

Cleaning and
implemented and maintained. Measures shall be in place
FSM 19.4 Disinfection
to verify the effectiveness of the cleaning and disinfection
Programme
programme.

A documented change management procedure shall be

Change
FSM 27 established, with particular emphasis on changes that could
Management
impact food safety.

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Part IV: Glossary of Terms

General updates:
• New definitions added in, and some existing ones
updated.

STRENGTHENED ELEMENTS

Part II: Requirements for the Governance

of Certification Programmes.
SECTION 1: Ownership, Development and Maintenance

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The Certification Programme Owner shall be a legal entity.

1.1 Ownership

The Certification Programme shall specify the use of off- product

Product
1.7 logo or mark and ensure that Certification Bodies communicate
Labelling
those rules to applicant / certified organisations.

Certification The Certification Programme shall be subjected to stakeholder

Programme consultation during its development.
1.10 Development
and
Maintenance

Certification The Certification Programme Owner shall inform key

Programme stakeholders, including GFSI, of any changes to the Certification
1.10 Development Programme, in particular all those changes that may impact
and the recognition status of the Certification Programme. (See
Maintenance Glossary for Reportable incidents to GFSI).

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The Certification Programme Owner shall ensure that the data

management system shall incorporate data in relation to the
GFSI Benchmarking Requirements and the annual assessment
questionnaire. This system shall allow to estimate as a minimum:

Data • Number of auditors approved to audit against the recognised

1.21
Management programme by region;
• Number of valid certificates;
• Number of issued certificates within a given period;
• Number of suspended certificates;
• Number of withdrawn certificates.

SECTION 2: Accreditation

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The Certification Programme shall include a certification

Certification process based on one of the following standards: ISO / IEC
2.1
Process 17065 for product Certification Bodies or ISO / IEC 17021-1 with
ISO 22003-1 for management system Certification Bodies.

DELETED
2.4 to 2.7

The Certification Programme Owner shall have a process in place

for communication exchange with the Accreditation Bodies:

Relationship
with • relevant information and developments related to the
2.8 Certification Programme;
Accreditation
• extending Certification Bodies’ scope of activities.
Bodies

Withdrawal or suspension of Certification Bodies for reasons

related to accreditation standard.

DELETED
2.9

Certification The Certification Programme Owner shall ensure that a list of

2.10
Bodies List active Certification Bodies is publicly available without request.

The Certification Programme Owner shall ensure that all

activities resulting in the issuing of certificates are delivered
Accreditation
by Certification Bodies accredited by Accreditation Bodies
2.12 of Certification
members of the International Accreditation Forum (IAF) and
Bodies
signatories to the Multilateral Recognition Arrangement (MLA)
for the appropriate scope.

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DELETED
2.15 & 2.16

In the event that accreditation is not granted within 12 months

or, in situations where there is a delay, the Certification Body
Accreditation
shall provide a plan to the Certification Programme Owner for
2.18 of Certification
approval to achieve accreditation and any potential impact
Bodies
on GFSI Recognition shall be highlighted to the GFSI Senior
Technical Manager.

2.20 Accreditation In the event that the range of certification services offered by a
of Certification Certification Body is wider than the range of those accredited,
Bodies the Certification Programme Owner shall mandate that the
Certification Body makes clearly and publicly available the
scope of their accreditation.

SECTION 3: Relationship with Certification Bodies

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The Certification Programme Owner shall agree on appropriate

Relationship actions with Certification Bodies to mitigate any situations
3.7 with Certification which could result in bringing their Certification Programme
Bodies or GFSI into disrepute, and notify GFSI of such situation (See
Glossary for Reportable incidents to GFSI).

The Certification Programme Owner shall implement a risk-

based programme of Certification Bodies office audits, focusing
on the implementation of the Certification Programme’s
requirements by the Certification Bodies.

Risk factors may include:

• the number of countries in which a Certification Body

3.13 Office Visits operates;
• the number of auditors employed;
• languages in which audits are undertaken;
• number of certified companies;
• number of centralised Certification Body offices;
• number of audits undertaken per auditor;
• grading and number of non-conformances;
• management and notification of product recalls to
Certification Programme Owner.

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SECTION 4: Certification Bodies Personnel

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The Certification Programme Owner shall ensure that a

Certification system is in place to ensure all personnel involved in the
4.1 Body Personnel certification process meet the competence required by the
Competence Certification Bodies, the Certification Programme and the GFSI
Benchmarking Requirements.

The Certification Programme Owner shall ensure that the

Certification Bodies require all personnel involved with the
certification process to sign a contract or agreement, which
Certification clearly commits them to:
4.2 Body Personnel
Competence • Complying with the rules of the Certification Body, with
particular reference to confidentiality, impartiality and
independence from commercial or personal interests;
• Declaring any issues in relation to personal conflicts of interest.

The Certification Programme Owner shall mandate that the

Certification Bodies clearly document all requirements of
ISO / IEC 17065 or ISO / IEC 17021-1 with ISO 22003-1, and
Certification
IAF MD4, relating to personnel and make them known to
4.3 Body Personnel
their employees. This shall include systems and procedures
Competence
to ensure that auditors conducting assessments meet the
capabilities described in ISO / IEC 17065 or ISO / IEC 17021-1
with ISO 22003-1 and the requirements of IAF MD4.

The Certification Programme Owner shall ensure that the

Certification Bodies hold and maintain records regarding the
qualifications, training and experience of all personnel involved
in the certification process. All records shall be dated. The
Certification information shall include, as a minimum:
4.4 Body Personnel • Name of trainees;
Competence • Affiliation to the Certification Body and position held;
• Educational qualifications and professional status;
• Experience and training in the relevant fields of competence
in relation to the Certification Programme’s requirements;
• Details of performance appraisal(s).

The Certification Programme Owner shall ensure that the

Certification Bodies have a system in place to ensure auditors
Auditor conduct themselves in a professional manner. This shall be
4.6
Behaviour evaluated through a defined witness audit process confirming
acceptable auditor performance as specified by the Certification
Programme Owner.

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The Certification Programme Owner shall ensure that

Auditors’ Certification Bodies appoint auditors with experience in the
4.8 Industry food or associated industry, including at least two years full time
Experience work in food safety functions and requirements defined in table
1, column 4.

The Certification Programme Owner shall ensure that

Scope Extension Certification Bodies require an auditor extending their scope of
4.11 of Auditor activity to undergo a programme including training in the new
Activities sector, supervised audits as per 4.10 and assessment and sign
off as competent in the new sector by the Certification Body.

The Certification Programme Owner shall have in place a

register of approved auditors including the details of the
auditors’ competence, education, relevant experience and
4.16 Auditor Register
scope(s) of activities, and applicable Certification Bodies. The
register shall remain current and be made available to GFSI
upon request.

SECTION 5: Management of Audit and Certification

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Irrespective of the defined minimum audit frequency,

Audit the Certification Programme Owner shall ensure that the
5.5 Programme – Certification Bodies undertake additional audits if there is
Audit Frequency evidence or suspicion that the integrity of the Certification is at
risk within a certified organisation.

The Certification Programme Owner shall ensure that

appropriate confidentiality is in place and that all audit
reports are only released at the discretion of the contracted
5.13 Audit Reporting
organisation. Ownership of the audit report, determination of
details made available and authorisation for access shall remain
with the contracted organisation.

The Certification Programme Owner shall ensure that

Certification Bodies have agreements in place with certified
Management organisations ensuring that the Certification Programme
5.28
of Certification Owner is informed of any significant public food safety
incidents, such as significant regulatory food safety non-
conformities, product recalls.

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SECTION 6: Multi-site Certification

Only the following scopes of recognition may be It shall be stressed that certification of multi-site
considered for certification of multi-site organisations, organisations based on sampling is not compulsory
based on a sampling of the sites: for a Certification Programme Owner within these
scopes of recognition and a Certification Programme
• AI Farming of Animals for Meat/Milk/Eggs/Honey Owner may opt for single site certification only.
• AII Farming of Fish And Seafood
• BI Farming of Plants (Other Than Grains and Pulses) Where a Certification Programme Owner permits the
• BII Farming of Grains and Pulses use of certification of multi-site organisations based
• BIII Pre-Process Handling of Plant Products, Nuts on sampling then the Certification Programme shall
and Grains satisfy the below GFSI Benchmarking Requirements.
• G Provision of Storage and Distribution Services

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The Certification Programme Owner shall clearly specify the

General
6.2 conditions for certification of multi-site organisations based on
Requirements
sampling for eligible scopes.

All sites included in the scope of certification of a multi-site

General
6.3 organisation shall operate under the same Food Safety
Requirements
Management System and under the control of a central function.

The central function shall ensure management commitment

to the system / integrity and clearly describe the roles and
6.8 Central Function responsibilities of management, internal auditors and other
members of the organisation. The central function shall be
separate from the sites.

An internal audit programme based on site and risk profile

shall be in place and undertaken by the central function. This
6.14 Internal Audit programme shall ensure audits of all sites within the scope
of certification, the central function and the Food Safety
Management System at least annually.

Internal auditors shall be assigned by the central function that

6.19 Internal Audit
are independent to the sites to ensure impartiality.

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The Certification Programme Owner shall have a system

in place for the Certification Bodies to define a risk-based
sampling programme that includes a minimum sample size
determined by the Certification Programme Owner.
Site Audit The sampling programme shall include provisions to increase
6.21
Sampling sample size based on various risk factors (e.g., audit scope,
types of activities on-site, findings of the central management
system audit, findings at sampled sites, customer requirements,
etc.), size of the group or multi-site organisation and the internal
structure as per IAF MD1.

The Certification Programme Owner shall ensure that

Site Audit
6.22 Certification Bodies audit a sample of the sites every year as
Sampling
per IAF MD1.

The annual sampling size of the Certification Body audit

sampling programme shall be based on IAF MD1 current
Site Audit version. The square root sample of the Certification Body’s
6.23 audit of the sites shall be calculated per risk category.
Sampling
The sampling programme can be adjusted based on the use of
monitoring technologies as per IAF MD1.

The programme shall be partly selective and partly non-

selective, but at least 25% of the sample shall be randomly
Site Audit
6.24 selected from the total number of sites. Selected sites shall be
Sampling
identified based on the organisation’s internal audit programme
findings and the site risk profiles as per IAF MD 1.

Non-conformities found on sites shall be assessed to ascertain

if these indicate an overall Food Safety System deficiency
Management
and therefore may be applicable to all or other sites. If non-
6.25 of Non-
conformities relate to all or other sites, corrective action shall
conformities
be undertaken and verified both by the central function and by
the Certification Body as per IAF MD1.

In the event that non-conformities are found when auditing sites,

Management which may not jeopardise certification but may raise concerns
6.26 of Non- on conformity of the organisation, the Certification Body shall
conformities increase the sample size to ensure adequate confidence in the
conformity of the organisation as per IAF MD 1.

A risk-based approach shall be in place to determine the

Site Audit eligibility of commodities. Certain crops or activities deemed
6.28
Sampling “high-risk” shall be risk assessed to determine their eligibility
for multi-site or group certification.

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PART III: Requirements for the Content of Standards

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A systematic Hazard and Risk Management System (or HACCP

system) based on the current version of Codex Alimentarius
Hazard and Risk
General Principles of Food Hygiene shall be implemented to
HACCP 1.1 Management
identify specific hazards, the measures for their control shall be
System
based on scientific evidence of risk to health. This system shall
take all relevant laws into consideration.

HACCP 1.1.1 to DELETED

HACCP 1.1.4

The scope of the Hazard and Risk Management System (or

Hazard and Risk HACCP system) and applicable prerequisite programmes shall
HACCP 1.2 Management be clearly defined in accordance with the product(s)/activities
System undertaken at the site and included within the sites scope
of certification.

The prerequisite programmes shall be designed, established

Hazard and Risk
and verified where possible, to support the application and
HACCP 1.3 Management
implementation of the Hazard and Risk Management System
System
(or HACCP system).

Hazard and Risk There shall be commitment from senior management for
HACCP 1.4 Management implementation of an effective Hazard and Risk Management
System System (or HACCP system).

A competent multidisciplinary team shall assess the hygienic

Hygienic Design
HACCP 1.5 design and risk assessment of new and existing buildings/
Process
equipment, including upgrade or improvements.

The hygienic design and suitability of new and existing buildings

Hygienic Design and equipment shall be assessed throughout their life cycle
HACCP 1.6
Process from the design concept, through construction, purchasing and
during use, until the end of their intended life.

The intended use of the building/equipment shall be described,

HACCP 1.9.2 Intended Use as a specification for the intended purchase or construction of
new buildings and equipment.

Hygienic Design Buildings and equipment shall be of a hygienic design, to meet

HACCP 1.11
Principles all cleaning objectives.

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A commitment from senior management to establish direction,

Management engage personnel, and provide sufficient resources to maintain
FSM 2
Commitment a positive food safety culture and continuously improve Food
Safety Management System shall be provided.

The senior management shall review all elements of the Food

Safety Management System, including the Food Safety Culture
Management plan, the Hazard and Risk Management System (or HACCP plan
FSM 3
Review or HACCP-based plans) regularly, and in case of any change
that impacts food safety, to ensure their continuing suitability
and effectiveness.

This food defence plan shall be developed, implemented,

FSM 7.3 Food Defence verified, maintained and reviewed on regular basis or when a
new threat is established.

The agent / broker shall ensure that their suppliers’ food defence
FSM 7.3.1 Food Defence plan is developed, implemented, verified, maintained and
reviewed on regular basis or when a new threat is established.

A documented food fraud management plan shall be in place

FSM 8.2 Food Fraud specifying the measures implemented to mitigate the public
health risks from the identified food fraud vulnerabilities.

This food fraud management plan shall be developed,

FSM 8.3 Food Fraud implemented, verified, maintained and reviewed on regular
basis or when a new vulnerability is established.

Specified requirements or specifications shall be established,

implemented and maintained for all inputs to the process,
Specified
including services that are purchased or provided and have an
FSM 10.1 Requirements /
effect on food safety. Microbiological, physical, chemical and
Specifications
allergenic specifications used for food safety purposes shall be
based on appropriate scientific principles.

An allergen management plan shall be established, implemented

and maintained. This shall include a risk assessment of allergen
Allergen
FSM 16.1 cross-contact, implemented controls to reduce or eliminate that
Management
risk, and labelling of the food in compliance with the allergen
labelling legislation in the country of intended sale.

An allergen management plan shall be established,

Allergen implemented and maintained. This shall include a risk
FSM 16.2
Management assessment of allergen cross-contact implemented controls to
reduce or eliminate that risk.

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Change control shall be undertaken and documented to evaluate

the impacts of any changes/modifications on equipment/
Change
FSM 26 building hygienic design and ensure that the organisation is
Management
equipped to ensure food safety during temporary, emergency
and unplanned changes.

The site, both the exterior and the interior, shall be designed,
Design, constructed and maintained to minimise food safety risks.
Construction,
GMP 3 The layout and flow of operations shall be suitable for the
Layout and Flow
of Operations intended purpose and designed in line with hygienic design
principles to minimise food safety risks.

Product Following purchase (and installation), all buildings and

Contamination equipment shall be cleaned/commissioned by the user before
GMP 4.11
Risk and they are used for the processing of food. Cleaning activites
Segregation shall should be recorded and verified.

Personal Hygiene, Suitable protective clothing and footwear shall be provided to

Protective Clothing minimise food safety risks.
GMP 6.2
and Medical
Screening

Procedures shall be established, implemented and

maintained to ensure that all employees including
GMP 7 Training temporary workers and subcontractors are trained, and
retrained as necessary to have an understanding in food
safety, commensurate with their activity.

Procedures for housekeeping, cleaning and disinfection shall

Housekeeping, be established, implemented and maintained. Their
GMP 8.1.1 Cleaning and effectiveness in minimising food safety risks shall be verified,
Disinfection based on the risks associated with the product or activity.

Cleaning activities shall not represent a food safety risk.

A procedure shall be established, implemented and maintained

Waste for the collection, storage and disposal of waste material,
GMP 12.1
Management including waste water and drainage ensuring they do not pose
any food safety risks.

All containers and vehicles used for transportation in a way

that could impact food safety shall be designed, constructed,
GMP 15 Transport
monitored and maintained to minimise food safety risks. They
shall be suitable for the intended purpose.

Location, Design The site facility shall be fenced and the entry points controlled.
GAP 3.3
and Layout For e.g. by lockable gates.

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The systems described under GAP 3.7 shall be designed and

Location, Design constructed to avoid potential for contamination of water
GAP 3.8.1
and Layout courses, highways and neighbouring fields with animal waste,
residual agricultral chemicals and silo seepage.

Feed shall be stored securely and handled to prevent cross

Prevention
contamination for e.g. separately from waste liquids, untreated
GAP 4.3 of Cross-
manure, hazardous substances, veterinary medication and
contamination
cleaning chemicals.

Prevention Procedures shall be in place to ensure that the application

GAP4.4.1 of Cross- of agricultural and veterinary inputs is managed properly to
contamination minimise the potential for contamination.

Prevention Procedures shall be in place to ensure that the application

GAP4.4.2 of Cross- of aquaculture and veterinary inputs is managed properly to
contamination minimise the potential for contamination.

Employee facilities including hand washing and toilet facilities,

Employee and public facilities where applicable, shall be provided,
GAP 5
Facilities designed, maintained, cleaned and operated to minimise food
safety risks.

Personnel Personnel hygiene standards shall be established, implemented

GAP 6.1 Health and and maintained to minimise food safety risks.
Hygiene

Personnel Where necessary suitable protective clothing and footwear

GAP 6.2 Health and shall be provided to minimise food safety risks.
Hygiene

A programme of site inspections and checks shall be established,

implemented, and maintained to confirm that these activities occur
at a frequency based on risk and any significant changes that
Site Inspections/
GAP 9 may impact food safety. The programme shall cover the site and
Checks
equipment to ensure they are maintained in a condition suitable
for safeguarding food safety, are relevant to the site’s activities
and verify that inspections and checks are conducted as required.

Indoor primary production facilities shall maintain a supply of

water fit for its purpose and that does not compromise food
GAP 11.1 Water Quality safety, for handwashing, irrigation, equipment and post-
harvest washing, with appropriate facilities for its storage,
and distribution.

Equipment shall be used, maintained, transported and stored to

GAP 18.2 Equipment
minimise food safety risk.

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