What Is HACCP (Food Safety Control System), and Who Must Implement It?

What Is HACCP?

HACCP stands for Hazard Analysis and Critical Control Point; in Taiwan's regulations it's called the "Food Safety Control System" (食品安全管制系統). The international prototype comes from the Codex Alimentarius Commission's General Principles of Food Hygiene (CXC 1-1969). Taiwan established the Regulations on Food Safety Control System (食品安全管制系統準則) under Article 8 of the Act Governing Food Safety and Sanitation; the current text was last amended on May 1, 2018.

Article 2 of the regulations defines it as using the principles of hazard analysis and critical control points to identify, evaluate, and control food safety hazards, managing the entire process from raw material receiving, processing, and manufacturing to storage and transport. The system must include 8 elements: forming a control team, conducting hazard analysis, determining critical control points, establishing critical limits, developing a monitoring plan, developing corrective actions, verifying the system's effectiveness, and establishing documents and records.

Take a bun factory as an example: the hazard analysis would list pathogens in raw meat, insufficient steaming temperature, metal foreign matter, and so on; if steaming is the key kill step, it may be designated a critical control point, with limits set for core temperature and time, and rules for who measures it, how often, and what to do when a measurement fails.

Mandatory Requirements for the Control Team and Records

• Team size: At least 3 people, and the person in charge or their designee must be included (Article 3).
• Training hours: Team members must complete at least 30 hours of courses at a recognized training institution and hold a certificate; while employed, they must accumulate at least 12 hours every 3 years (Article 4).
• Internal audits: At least once a year (Article 10).
• Internal training: At least once a year (Article 11).
• Record retention: At least 5 years, signed and dated by the person in charge or a designee (Article 12).

Do I Need to Implement HACCP?

The regulations only describe "how to do it"; whether it's mandatory depends on the sectors and scales announced by the TFDA under Article 8, Paragraph 2 of the Food Safety Act. The current notices found in the TFDA's regulatory information at the time of writing are:

• Seafood processing (amended March 17, 2026): Products containing 50% or more aquatic animal ingredients; businesses required to have factory registration with 5 or more food workers, or with commercial or company registration, 5 or more workers, and capital of NT$30 million or more.
• Meat processing (amended March 17, 2026): Products containing 50% or more livestock or poultry meat or offal; scale conditions are the same as for seafood.
• Dairy processing (amended March 17, 2026): Businesses required to have factory registration, or with commercial or company registration, 5 or more workers, and capital of NT$30 million or more.
• Factories producing heat-sterilized, hermetically sealed low-acid and acidified foods (amended March 17, 2026, i.e., canned foods): Factory registration required, with capital of NT$30 million or more, or under NT$30 million but with 5 or more workers.
• Egg product factories and edible oil and fat factories (announced May 8, 2018).
• Meal box food factories (announced August 11, 2014) and food businesses supplying meal boxes to railway passengers (announced May 28, 2020).
• Restaurants attached to hotels (announced November 17, 2017): Restaurants in international tourist hotels and five-star hotels.

What About Frozen Food Businesses?

None of the notices found at the time of writing covers the "frozen food industry" as a whole. Whether a frozen dumpling or bun factory falls within the mandatory scope depends on the product contents: for example, the notice for meat processing covers products with 50% or more livestock or poultry meat or offal, plus scale conditions such as factory registration and the number of workers. Businesses should compare their own recipes and registration status with the original text of the notices, or confirm with their local health bureau. Notices are amended, so check the latest version in the TFDA's regulatory information before making a formal determination.

Businesses outside the mandatory scope can also adopt HACCP voluntarily; export customers and large retail chains often make it one of their supplier requirements.

How HACCP Relates to Machinery

Common physical hazards in HACCP include metal fragments, plastic fragments, and loose screws, all of which relate to equipment. Plants that implement HACCP usually require equipment that is easy to disassemble and wash, with parts that don't easily come loose, and include equipment cleaning, maintenance, and metal detection in their prerequisite programs. For design principles on the equipment side, see hygienic design principles; for how it differs from international certification, see What Is ISO 22000.

FAQ

Q: What's the difference between HACCP and GHP?
A: GHP is the basic hygiene standard all food businesses must follow; HACCP is a management system built on GHP that performs hazard analysis for products, sets critical control points, and monitors them continuously. It's mandatory only for sectors designated by public notice.

Q: Does a factory making frozen meat buns have to implement HACCP?
A: It depends on the notice conditions. The notice for meat processing covers products containing 50% or more livestock or poultry meat or offal, with scale conditions such as factory registration and 5 or more workers. Compare your product recipes and registration status with the original text of the notice.

Q: How many hours of training does the HACCP control team need?
A: Under Article 4 of the Regulations on Food Safety Control System, members must complete at least 30 hours of training and obtain a certificate, then accumulate at least 12 hours every 3 years.

Q: How long should HACCP records be kept?
A: Article 12 of the regulations requires at least 5 years.