When do you update your HACCP plan?
You update your HACCP plan as soon as reality no longer matches it. Examples are a new product, different equipment or a complaint that shows a risk is not properly controlled. HACCP stands for Hazard Analysis and Critical Control Points. Article 5 of Regulation 852/2004 states that you must review and adapt the procedure when you change the product, the process or a step in it, and that the documents must always be up to date. The NVWA (Netherlands Food and Consumer Product Safety Authority) puts it this way: “Check regularly whether your HACCP approach is effective.” The sixth of the 7 HACCP principles, verification, is the basis for this.
A HACCP plan that has not been updated for five years, while the menu has changed, is in practice out of date. Such a plan quickly stands out during an inspection.
What does the NVWA say about this?
The law gives one clear trigger: a change in product, process or step (Article 5 of Regulation 852/2004). Neither the regulation nor the NVWA page names a fixed period or a list of cases. That is why it is sensible to put a clear agreement in your own plan: which events lead to a review, and who decides.
The seventh principle also requires you to record what you do. A change without a note is, in practice, a step backwards. See documentation and record keeping in the 7 principles for the background. How long you keep old versions and records is set out on how long to keep HACCP records.
Events that require a review
The list below is a practical working-out of that trigger, not a legal list. Include the situations that are relevant to your business.
| Situation | What must change | Example |
|---|---|---|
| New product or new dish | Hazard analysis and, if needed, CCPs | A raw fish special on the menu |
| New equipment | Limit values and monitoring | A different cold room or combi oven |
| Renovation or new layout | Process flow diagram and separation | A separate route for dirty and clean |
| New supplier with a different product | Goods-in check and hazard analysis | A different meat supplier with different packaging |
| Complaint or incident | Root cause analysis and, if needed, an extra CCP | A customer ill after a cold buffet |
| Deviation during a check | Corrective action and tighter monitoring | Cold room above the limit value several times |
| Change to the hygiene code | Move to the new version | New version of the hospitality hygiene code |
| Change of staff or person in charge | Update the HACCP team and contact persons | A new head chef |
Note the last row. A plan that still names a former chef as the person in charge is a small error that raises a lot of questions.
Example of a change log
Record every change in a log with the plan. This does not need to be complicated.
| Version | Date | Change | Reason | By | Approved by |
|---|---|---|---|---|---|
| 1.0 | March 2025 | First version, hazard analysis for the kitchen | Start of HACCP | Owner | Owner |
| 1.1 | June 2025 | Addition of terrace service with a cold buffet | New product | Owner | Owner |
| 1.2 | October 2025 | Limit value for cold room 2 adjusted after a deviation | Complaint and check | Head chef | Owner |
| 1.3 | March 2026 | New combi oven, core temperature adjusted | Equipment | Head chef | Owner |
The version and the date should also appear on the front of the plan. An inspector looks there first.
How do you carry out a change?
A good review follows a fixed order. First, you describe what is changing and why. Then you check which hazards are new or are now assessed differently. Next, you adjust the CCPs, limit values and records. Finally, you record the new version and brief the staff.
Do not skip that last step. A new limit value that is on paper but unknown on the kitchen floor has not been implemented. An inspector will check this. For what you need to show, read NVWA inspection of HACCP.
Common mistakes
- Making a change without updating the plan, so that the plan and the kitchen contradict each other
- Lowering or raising a limit value without a justification
- Not raising the version number, so it is not clear what differs between the old and new plan
- Updating the plan only when an inspection is due. This looks like administration tidied up after the fact
Is an annual check enough?
A full annual review of the plan is a good safety net, but it is not enough if things change in between. Combine the annual check with a fixed trigger: every change to the menu, equipment, staff or suppliers counts as a reason to review. That keeps the plan up to date without a full review every month.
Further reading on your HACCP plan
- The plan itself, with its parts and a completed example, is on HACCP plan example.
- The CCP decision tree helps when you determine new CCPs.
- For the checklist to see whether the system is still complete, see the HACCP checklist.
Frequently asked questions about updating your plan
Do I have to update my plan for every small change?
No. A small adjustment, such as a new supplier for the same product, can go in the change log without a new hazard analysis. A new product or new equipment does require a fresh assessment.
What if the hygiene code for my sector changes?
Then you assess whether the change applies to your business. Adopt the new version and record in the log which parts you have adjusted.
Can I have an adviser check my plan?
Yes, and this is sensible for major changes. The responsibility stays with your business. An adviser helps with choosing limit values and CCPs, but the choices must match your actual process.
Sources
- NVWA: Working according to the HACCP system , including the passage on checking the effectiveness regularly
- Regulation (EC) No 852/2004 on food hygiene , Article 5 on HACCP procedures