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FOOD LOSS AND WASTE · FSSC 22000 CLAUSE 2.5.16 B AND C
Key facts
- Hierarchy rank, donation second, behind prevention only
- Hierarchy rank, animal feed third
- Governing clause FSSC 22000 additional requirement 2.5.16 b and c
- Core requirement the diversion must be recorded and traceable
- Test an auditor uses trace one donated batch end to end
- Minimum controls batch traceability, correct temperature, dated documentation
- Related clauses BRCGS Food Issue 9 clause 4.12 and 4.13
- Course that covers this Reducing Food Loss and Waste, R1195
Turn the baseline into a funded, audit ready programme
Reducing Food Loss and Waste for Sustainable Manufacturing teaches you to cost the losses, write the policy and objectives, and route surplus to donation or animal feed safely.
Enrol in Reducing Food Loss and Waste, R1195
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Self paced online with lifetime access. About eight hours in total, including a hands on programme workshop.
Why donation and animal feed sit near the top of the hierarchy
The food recovery hierarchy ranks prevention first, feeding people through donation second, and feeding animals third, ahead of industrial uses, recycling, recovery and disposal. Surplus that is genuinely fit for human consumption but will not be sold through normal channels, an overrun, a labelling change, a short dated batch, is exactly the material this part of the hierarchy exists for. Choosing donation over disposal is the right call on paper. What decides whether it is the right call in practice is whether the controls behind it hold up.
What FSSC 22000 clause 2.5.16 b and c actually require
Clause 2.5.16 b and c set out the controls that apply once a site decides to route surplus food or inedible material to donation or animal feed instead of disposal. In outline, the diversion has to be recorded and traceable back to the batch it came from, the material has to continue to meet the food safety and quality requirements appropriate to where it is going, and the site has to be able to account for it if asked during an audit or a recall exercise. The controls do not stop at the gate. They exist to make sure a good intention does not become the weak link the rest of the food safety system was built to close.
Donation without traceability is not a food safety decision, it is a gap waiting to be found in a mock recall.
Turn this into a certificate your auditor can check
Food Loss and Waste Essentials teaches operators, packers and supervisors to sort what comes off a line into the right pile and say why, using one real production day from gate to pallet.
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Self paced online with lifetime access. About five hours in total. QR verified Certificate of Achievement.
The controls a donation route needs before product leaves the gate
Minimum controls for a controlled surplus donation route
- Batch traceability preserved from production through to the receiving organisation
- Named authorisation for the decision to divert, not an informal call on the loading dock
- Date and specification checks matched to the receiving destination’s requirements
- Correct transport temperature maintained for the product’s storage class
- A dated record of what left, the quantity, and who received it
- The diverted volume reflected in the food loss and waste baseline, not left out of it
Matching the controls to the destination
Donation and animal feed are not interchangeable routes with interchangeable rules. Donation moves food that is still fit for human consumption to people, so it carries the full weight of food safety and, where applicable, labelling requirements that any product reaching a consumer carries. Animal feed uses material that is often no longer suitable for human consumption but is still safe and nutritionally useful, and carries a different set of legal and quality requirements suited to that use. Treating both routes the same way, or worse, treating either as exempt from control because no money changes hands, is where donation programmes tend to fail on inspection.
How an auditor actually tests this
An auditor checking clause 2.5.16 b and c evidence will typically ask to trace one specific donated batch end to end, in the same way they would trace a batch through a mock recall: which production run it came from, who authorised the diversion, how it was transported, and who received it, with dates and names at every step. A site with clean sales records but no equivalent trail for what it gave away has a real gap under this clause, and volume or good intentions do not close it. Building that trail from the start, rather than reconstructing it after the fact, is the difference between a donation programme that earns its place on the hierarchy and one that quietly does not.
Food Loss and Waste Essentials, R599 · Measuring Food Loss and Waste, R995 · Reducing Food Loss and Waste for Sustainable Manufacturing, R1195
See the full food loss and waste course pathway or browse all ASC courses. Related guides: every food loss and waste article.
Build the number an auditor cannot pick apart
Measuring Food Loss and Waste teaches QA and technical managers the scope, quantification method and mass balance discipline behind a defensible clause 2.5.16 baseline.
Enrol in Measuring Food Loss and Waste, R995
See the full food loss and waste pathway
Self paced online with lifetime access. About seven hours in total, including a hands on baseline workshop.
Frequently asked questions
Is it safe to donate surplus food from a manufacturing site?
Yes, provided the surplus is still fit for human consumption and the same controls that apply to any product leaving the site apply to the donated stream: traceability back to batch, correct temperature control in transit, and a clear record of what left, when, and to whom. Donation without those controls is not a food safety decision, it is a gap waiting to be found in a mock recall.
What does FSSC 22000 clause 2.5.16 b and c require for surplus donation and animal feed?
Clause 2.5.16 b and c set out the controls that apply once surplus food or inedible material is routed to donation or animal feed rather than disposal, including that the diversion is recorded and traceable, that food safety and quality requirements appropriate to the destination are met, and that the site can account for the material if it is asked to during an audit or a recall exercise.
Can a not for profit accept any surplus food a manufacturer offers?
No. A receiving organisation still needs the product to be within date, correctly labelled where labelling is legally required for the destination, and transported at the temperature the product needs. A donation programme that skips those checks to move volume quickly is the fastest way to turn a good intention into a food safety incident, and it undoes the credit the diversion was meant to earn under the hierarchy.
What is the difference between routing surplus to donation and to animal feed?
Donation moves food that is still fit for human consumption to people, and sits second on the food recovery hierarchy behind prevention. Animal feed uses material, often no longer suitable for human consumption but still safe and nutritionally useful, and sits third on the hierarchy. Both require controls, but the food safety and legal requirements that apply to each destination are different and need to be matched correctly.
How would an auditor test whether a site’s donation programme is actually controlled?
By asking to trace a specific donated batch end to end: which production batch it came from, who authorised the diversion, how it was transported, and who received it, in the same way an auditor would trace a batch through a mock recall. A site that can produce sales records for its product but not a matching trail for its donations has a gap under clause 2.5.16 b and c, whatever the volume of goodwill involved.
Which course covers the surplus decision route and these controls in full?
Reducing Food Loss and Waste for Sustainable Manufacturing. It teaches the surplus decision route and every control clause 2.5.16 b and c requires for donation and animal feed, with traceability built to survive a mock recall, as part of turning a measured baseline into a funded, audit ready reduction programme.
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