What is HACCP and what role do packaging and crates play? 

HACCP (Hazard Analysis and Critical Control Points) is a system for identifying and managing food safety risks. Every food business in the EU is required to operate in accordance with the HACCP principles. In this context, packaging means more than just the immediate wrapping: crates and other containers are also considered both a control measure and a potential risk within the system. 

The seven principles of HACCP 

The system follows seven fixed steps, as laid down in the Codex Alimentarius: 

• Identify all hazards: microbiological, chemical and physical. 

   

• Identify the critical control points (CCPs) where these hazards can be controlled. 

   

• Set critical limits for each CCP, such as a maximum temperature. 

   

• Set up monitoring to monitor each CCP continuously or on a random basis. 

   

• Establish corrective actions to be taken should a limit be exceeded. 

   

• Periodically verify that the system is functioning as intended. 

   

• Document everything, from hazard analysis to measurements and corrective actions. 

Many companies follow an industry-specific hygiene code that already translates these steps into specific requirements. 

The legal basis 

HACCP is enshrined in the EU in Regulation (EC) No 852/2004 on food hygiene. This requires every business that produces, processes or distributes food to have a food safety plan based on HACCP. 

The regulation allows for a tailored approach. Small businesses may apply the principles proportionately, provided that food safety remains demonstrably guaranteed. 

Regulatory bodies such as the NVWA in the Netherlands and the FAVV in Belgium monitor compliance. Certification schemes such as BRCGS, IFS and FSSC 22000 are based on the same principles, often with additional requirements regarding packaging and carriers. 

Prerequisite programmes as a foundation 

HACCP only works on a solid foundation of basic prerequisite programmes. These include cleaning and disinfection, pest control, personal hygiene and the maintenance of buildings and equipment. 

The management of packaging and containers belongs on that list. Procurement requirements, the storage of empty crates and the handling of returnable containers are all regulated within the prerequisite programmes, even before the hazard analysis begins. 

If you have the basics in order, you’ll end up with a clear and well-organised HACCP plan. The risk analysis then only needs to monitor the truly critical points, rather than every single hygiene detail. 

Packaging as a control measure 

In the context of HACCP, packaging comprises three layers: the primary packaging that comes into direct contact with the food, the secondary packaging that bundles products, and the logistical carriers such as crates and pallets. 

A crate can fulfil different roles in this context. If loose bread, meat or fish is placed directly inside the crate, the crate acts as the primary packaging and the full material requirements of Regulation (EU) No 10/2011 apply. If the product is already wrapped in cling film or a bag, the crate acts as a carrier with no direct contact with the food; however, the hygienic and physical risks remain part of your hazard analysis. 

In both roles, a sound crate protects against the hazards that HACCP aims to control: moisture, dirt, pests and physical damage during storage and transport. 

At the same time, the packaging itself can pose a hazard. Non-food-safe materials, loose particles or residual contamination from a previous use are typical risks that you should include in your hazard analysis; you mitigate the chemical risk by using compliant materials, and the physical and microbiological risks through inspection and cleaning. 

Hygiene and cleanability of containers

Reusable crates go through many cycles and must start each cycle clean. Smooth surfaces without seams or wood fibres can be industrially washed and dry quickly. 

Include the washing process in your HACCP plan. Washing temperature, detergent and visual inspection after washing are logical monitoring points. 

From plan to the workplace 

An HACCP plan only works if staff are familiar with it and apply it. Brief work instructions for each CCP make the limit values and corrective actions immediately visible right where the work is carried out. 

Furthermore, keep the plan up to date. Any change to the product, process, supplier or packaging is a reason to review the hazard analysis. 

This also includes switching to a different type of crate. Different materials, walls or washing procedures can either reinforce or undermine existing control measures. 

Traceability in your HACCP plan 

In the event of an incident, you want to know quickly which batches are affected. Crates with barcodes or RFID tags link each cycle to a batch, location and time. 

This record-keeping limits the scope of a recall and speeds up the root cause analysis. Traceability at container level also makes your verification process demonstrable during audits. 

View our crates for the food industry