Annex 1 (中文/英文) of the Scheme describes the rules for the scope statements on the FSSC 22000 certificate. This article provides further clarification on the use of claims and other products not included or partially included in the scope of certification.
1. Guidance on the use of Claims
The certificate scope statement shall not include promotional statements or claims.
Claims being any message or representation:
• That is not mandatory under legislation and,
• That suggests that the food or service has particular characteristics.
Examples include health claims, nutritional claims, origin claims, free-from claims (e.g. allergen free claims), organic and quality claims.
There are some instances where claims are allowed to be included in the scope statement as set out below:
• Where it is mandatory under legislation
• Use of the word natural under certain conditions
a) Claims mandatory under legislation
Claims mandatory under legislation are allowed to be used in the scope statement. Mandatory meaning that it is not possible to produce the relevant product in any other way than under the relevant legislation in the country.
Example: Gouda Cheese
In cases where it is a decision by the company to produce a product in a certain way i.e. organic or gluten-free and legislation exists relating to organic or gluten-free status, then it is not seen as mandatory legislation in the context of this article and is considered to be a claim that cannot be included in the scope wording.
b) Use of the word natural
The word natural may only be used when it is inherent to the product and the following conditions are met:
i. No alteration of the original product takes place other than physical extraction of the raw material, natural processing (e.g. drying in the sun, filtering and washing) and packing and
ii. No further processing or chemical intervention takes place.
Examples:
• Sugar from pressing sugar cane. The product may be called natural sugar if it only undergoes a pressing process and is not refined or altered.
• Water from a natural source. Water from a well which is bottled without processing. The product may be called natural water.
• Natural color: color extracted from a natural source (e.g. insects, plants etc.). The product may be called a natural product where no further processing or chemical intervention takes place. Physical extraction is allowed.
c) Obligation of the auditor
Where an organization makes any claims, this shall be included and investigated during the audit and reported in the audit report, including but not limited to the legislative requirements.
d) Decision tree on the use of claims
In all instances the scope wording shall not be ambiguous and care needs to be taken when compiling the scope statement to ensure it is not misleading. Annex 1, section 4.2 references where products are intended for specific vulnerable consumer groups, this shall be indicated in scope statement for instance food for baby’s, hospitals etc. When referencing hospitals this needs to be put in context of the product’s intended use and not imply that the product is medicinal.
2. Disposable Tableware
Part 1 of the Scheme – section 3.7 states that disposable tableware can only be certified when it is sold together (and as part of) the food product. Examples are spoons that are packed with yogurt and utensils such as forks or chopsticks packed with ready to eat food.
The main consideration is whether the disposable tableware is sold together and as part of the food product. When looking at paper cups used in restaurants to serve beverages, the paper cup is sold with the beverage and as part of the food product, so may be included in the scope of certification.
Where a manufacturer produces disposable tableware with multiple outlets/customers (e.g. restaurants, retailers) as could be the case in the paper cup example, the full production process shall still be audited as it is the same process, but the scope statement on the FSSC certificate shall be restricted to the intended use e.g. The production of paper cups for use in the food industry and intended for sale as part of the food product.
Paper cups produced to be sold in retail cannot be included as it is not sold as part of the food product.
