Last updated 4 October 2026
FSSC 22000 clause 2.5.16 asks a certified site for four things: a food loss and waste policy and objectives, controls on donated products, management of surplus meant for animal feed or food, and legal compliance. ISO 20001:2026 asks for a full management system around food loss and waste, from scope to internal audit, management review and corrective action. The two overlap heavily, but overlap is not equivalence: meeting 2.5.16 does not mean you meet ISO 20001, and the reverse is also true.
Your FSSC 22000 certificate is current. Your 2.5.16 procedure passed the last audit. Your objectives sit in a register with owners and dates. Then a customer asks whether you plan to align with ISO 20001, and someone in the management meeting says: we already comply, we have 2.5.16. That sentence is wrong, and putting it in writing to a retailer is a risk.
Implementing ISO 20001:2026 Food Loss and Waste Management Systems puts clause 2.5.16 and ISO 20001 side by side and shows a certified site how to extend the system it already runs: 31 lessons, about 8 hours online, Advanced Level 4, R1 795 until 31 December 2026.
ISO 20001 and FSSC 22000 clause 2.5.16: the key facts
| Clause 2.5.16 | Four requirements, a) to d): policy and objectives, donated products, surplus for feed or food, legal compliance |
|---|---|
| Applies to | FSSC 22000 sites in all food chain categories except I (packaging manufacture) |
| Version 7 change | Objectives supported by clear and measurable targets with defined timelines |
| Version 7 timing | Version 6 audits allowed until 30 April 2027. Upgrade audits 1 May 2027 to 30 April 2028 |
| ISO 20001:2026 | A full food loss and waste management system, clauses 4 to 10. Published 29 September 2026 |
| The relationship | Heavy overlap. Neither satisfies the other |
What does FSSC 22000 clause 2.5.16 require?
Clause 2.5.16 asks for a documented policy and objectives to reduce food loss and waste in the organisation and its related supply chain, controls so that donated products are safe to consume, management of surplus or by-products meant as animal feed or food to prevent contamination, and compliance with applicable legislation (FSSC 22000 Scheme Version 7, Part 2).
FSSC 22000 is the GFSI benchmarked scheme that has written a dedicated food loss and waste requirement, clause 2.5.16. BRCGS, SQF and IFS deal with waste through their waste handling clauses. That makes FSSC 22000 sites the natural starting point for ISO 20001, and the sites most likely to assume they are already there.
What changed in clause 2.5.16 in FSSC 22000 Version 7?
One sentence. Version 7 keeps the wording of a) to d) and adds to a): “Objectives shall be supported by clear and measurable targets with defined timelines.” The related supply chain wording was already in Version 6.
That sentence lands at your upgrade audit. An objective that says “reduce food waste” with no baseline, unit or date will not survive it. See food loss and waste policy and objectives under FSSC 22000 and how to calculate food loss and waste.
ISO 20001 vs FSSC 22000 2.5.16: how do they compare side by side?
ISO 20001 applies every Harmonized Structure clause from 4.1 to 10.2 to food loss and waste. Clause 2.5.16 has four requirements. Where 2.5.16 is silent, a certified site usually has the machinery but not the food loss and waste content in it.
| Area | ISO 20001:2026 | Clause 2.5.16 |
|---|---|---|
| Policy | 5.2 | a) documented policy |
| Objectives | 6.2: measurable, monitored, with plans | a) objectives, with measurable targets and timelines in Version 7 |
| Context and interested parties | 4.1 and 4.2 | Not asked. a) mentions the related supply chain |
| Scope | 4.3: a documented scope | Not asked |
| Leadership and roles | 5.1 and 5.3 | Not asked |
| Quantification and reporting | Quantify, measure, monitor, document and report (ISO abstract) | Not asked directly |
| Donation | Safe redistribution, high on the hierarchy | b) donated products safe to consume |
| Animal feed | Next option once food is unsuitable for people | c) prevent contamination |
| Legal requirements | Policy commitment to satisfy applicable requirements | d) comply with applicable legislation |
| Competence, awareness, communication | 7.2, 7.3 and 7.4 | Not asked |
| Internal audit and management review | 9.2 and 9.3 | Not asked |
| Corrective action | 10.2 | Not asked |
| Certification | Certification or self-declaration. ISO/DIS 20020 still a draft | Audited within FSSC 22000 certification |
Where do ISO 20001 and clause 2.5.16 overlap?
In four places: the policy, the objectives, safe donation and surplus for feed, and legal compliance. One set of records can serve both, as long as you map each record to each requirement and never claim that one satisfies the other.
A signed policy, an objectives register with baselines, a donation procedure with a written agreement, a feed specification and a legal register that lists NEMWA section 16 carry weight in both audits. For donation, see donating surplus food safely.
What does an FSSC 22000 certified site still have to build for ISO 20001?
The system around the records: a scope, food loss and waste in the context and interested parties registers, leadership that signs, change control, competence and communication along the chain, contractor verification, internal audit, management review and corrective action.
- A scope statement, with the boundary for material that leaves the site (4.3)
- The feedlot, redistribution partner and contractors in the interested parties register (4.2)
- A named system lead with authority to act (5.3)
- Change control that catches a lapsed feed contract (6.3)
- Induction for seasonal workers (7.3) and a communication plan with growers and customers (7.4)
- Verified paperwork for every contractor and destination
- Food loss and waste in the internal audit programme, management review and CAPA system (9.2, 9.3, 10.2)
In the ASC course case study, an FSSC 22000 certified processor with a working 2.5.16 procedure scored 29 out of 84 on its ISO 20001 gap assessment. Its registers, audit programme and management review did not mention food loss and waste outside that procedure. The case is a training scenario built from real audit patterns, scored in how to run an ISO 20001 gap assessment.
Your registers, audit programme and management review already exist. The ISO 20001 implementation course shows where food loss and waste joins each one. Lock in R1 795 before the price moves to R2 495 on 1 January 2027.
What should you tell a customer who asks about ISO 20001?
Tell them what you assessed, what you found and when your plan goes to management review. Do not write “we comply with ISO 20001 through FSSC 22000”. The claim is not true, and a customer auditor can test it in an hour.
A one page dated position statement works. For what certification means today, read ISO 20001 certification in South Africa. For the basics, ISO 20001:2026 explained.
Frequently asked questions
Does ISO 20001 replace FSSC 22000 clause 2.5.16?
No. FSSC 22000 sites must still meet clause 2.5.16, and ISO 20001 is a separate voluntary standard. They overlap heavily, but neither satisfies the other.
If we meet clause 2.5.16, do we meet ISO 20001?
No. ISO 20001 adds scope, interested parties, leadership, communication, internal audit, management review and corrective action for food loss and waste.
Has FSSC announced an ISO 20001 scheme?
No. FSSC’s Technical Director took part in developing ISO 20001 and FSSC welcomed its publication, but no scheme had been announced as at 4 October 2026.
What changed in clause 2.5.16 in FSSC 22000 Version 7?
Objectives must now be supported by clear and measurable targets with defined timelines. The rest of a) to d) is unchanged.
When do FSSC 22000 Version 7 upgrade audits start?
On 1 May 2027, running to 30 April 2028. Version 6 audits remain allowed until 30 April 2027.
Does clause 2.5.16 apply to packaging manufacturers?
No. It applies to all food chain categories except category I, packaging manufacture.
Which ASC course covers ISO 20001 and clause 2.5.16?
If your site holds FSSC 22000, most of the machinery is there. Implementing ISO 20001:2026 Food Loss and Waste Management Systems ends with a gap list and a dated plan you can table before your Version 7 upgrade audit.
R1 795 until 31 December 2026, then R2 495. No VAT is charged, so the price shown is the price paid. Five or more learners: contact ASC for a team rate.
- 31 lessons in 8 modules, about 8 hours, on any phone
- 29 diagrams and case study packs with model answers
- A gap assessment tool that scores 28 items and exports an xlsx workbook
- A scope and interested parties builder and a clause sorting activity
- 7 knowledge checks, 6 timed games, a final assessment and one assignment marked against a published rubric
- 70 percent to pass, three attempts, and a QR verified Certificate of Achievement, Advanced Level 4
- Is it worth it if we are already certified? Yes. You extend one system instead of starting a second, and the gap list goes straight to management review.
- How long does it take? About 8 hours in short lessons, on any phone.
- Will it work at my site? The method works for a bakery, a meat plant, a dairy or a distribution centre. The tools take your own data.
Newer to the subject? Start lower on the ASC food loss and waste training ladder with Food Loss and Waste Essentials, Measuring Food Loss and Waste or Reducing Food Loss and Waste for Sustainable Manufacturing.
ISO 20001 is copyright and is not reproduced here. ASC is not affiliated with ISO.
Sources
- FSSC 22000 Scheme Version 7, Part 2, clause 2.5.16
- ISO 20001:2026, ISO standard page, checked 4 October 2026
- FSSC, ISO 20001 publication article, 30 September 2026