TABLE OF CONTENTS

About This eBook3

Executive Summary4

1. Why Food Loss & Waste Matters — The Global Picture5
2. Food Loss vs Food Waste — Definitions & Scope6
3. The Food & Drink Material Hierarchy8
4. Where Losses Occur in Food Manufacturing9
5. The Six Root Causes Behind Food Loss & Waste10
6. Measuring Food Loss & Waste — Target, Measure, Act11
7. New Requirements — FSSC 22000 Version 7, Clause 2.5.1613

7.1  Managing Donated Products13

7.2  Managing Surplus Products & By-Products13

7.3  Food Safety Culture (2.5.8) & Measurable Objectives (2.5.9)14

7.4  Category-Specific Guidance (E, F, G, K)14

8. Practical Improvement Ideas15
9. Guidance for Auditors16
10. Your Food Loss & Waste Transition Roadmap17
11. Implementation Checklist18

References19

ABOUT THIS EBOOK

This guide was developed from the Entecom Industry Support Webinar, “Reducing Food Loss & Waste: Practical Strategies for the Food Industry,” presented by Lyndri Fourie, Food Safety Consultant and EO Builder at Entecom. It is designed to help Food Safety Managers move beyond general awareness of food loss and waste (FLW) and build a clear, structured, and measurable programme that satisfies the requirements introduced by the GFSI Benchmarking Requirements 2024 and FSSC 22000 Version 7.

The content combines three things: the practical, operational guidance shared during the webinar — where losses actually occur on a production site, why they happen, and how to measure them; the specific normative requirements written into the FSSC 22000 Version 7.0 Scheme (published by Foundation FSSC in May 2026); and the detailed implementation guidance, definitions, and audit questions published in FSSC’s own official Guidance Document on Food Loss and Waste. Where possible, specific Scheme clause references are provided to support further reading and audit preparation.

Who This Guide Is For

Food Safety Managers, quality managers, internal auditors, operations managers, and sustainability leads at organisations certified — or working towards certification — under FSSC 22000, or any other GFSI-recognised scheme, who need to understand and implement food loss and waste requirements in a practical, evidence-based way.

EXECUTIVE SUMMARY

Food loss and waste (FLW) has moved from being a sustainability side-conversation to a formal, auditable requirement within the world’s leading food safety certification schemes. FSSC 22000 introduced a dedicated, measurable requirement — Clause 2.5.16, Food Loss and Waste — first published alongside Version 6 in 2023 and carried forward and reinforced in Version 7.0.

This shift is not accidental. FSSC’s own guidance points to the Champions 12.3 2022 Progress Report on UN Sustainable Development Goal (SDG) target 12.3, which found that approximately 8% of all food produced globally is lost at farm level, 14% is lost between the farm gate and retail, and 17% is wasted at retail, food service and household level. Food loss and waste also generate 8–10% of global greenhouse gas emissions annually and cost the global economy more than US$1 trillion a year. FSSC 22000’s Clause 2.5.16 is Foundation FSSC’s direct, practical contribution toward SDG 12.3 — halving food waste and reducing food losses by 2030 — translated into something a certified site can actually implement and be audited against.

For Food Safety Managers, the message of this eBook is straightforward: you almost certainly already generate the operational data you need. Receiving rejections, storage write-offs, changeover losses, packaging rejects, and expired finished goods are everyday events on any production site. What the Scheme now requires is that this information is captured deliberately, analysed for trends, tied to a documented policy with measurable targets, and reviewed as part of your management system — not simply noted and forgotten.

This guide takes you from understanding why FLW matters, through the official FSSC food waste hierarchy and where losses occur inside a typical food manufacturing operation, to the specific clause-level requirements — including donated product controls, surplus/by-product management, and category-specific expectations — and finally to a practical Target-Measure-Act roadmap and checklist you can start using immediately.

1. Why Food Loss & Waste Matters — The Global Picture

Before looking at production lines, receiving docks and dashboards, it’s worth zooming out. Food loss and waste isn’t only a challenge for one business or one factory floor — it’s a global one, and it’s why regulators and certification schemes are now paying such close attention to it.

Figure 1: The scale of global food loss and waste [Source: Champions 12.3, SDG Target 12.3 2022 Progress Report, as cited in the FSSC 22000 Guidance Document: Food Loss and Waste]

Together, that’s close to 40% of all food produced globally being lost or wasted somewhere along the chain — from farm, through processing and retail, to the household. The environmental cost is just as significant: food loss and waste generate 8–10% of global greenhouse gas emissions annually.

This is also a food security issue. Nearly 1 in 10 people worldwide are undernourished, while more than 2 billion tonnes of food each year never gets consumed. The United Nations’ SDG target 12.3 commits the world to halving per-capita food waste at the retail and consumer level, and reducing food losses along production and supply chains, by 2030. FSSC 22000’s Clause 2.5.16 exists specifically to help certified organisations contribute to that target.

We can’t solve the world’s food waste problem from a single factory floor. But we can ask a much more useful question: what does food loss actually look like inside our own operation — and what does it now mean for our certification?

2. Food Loss vs Food Waste — Definitions & Scope

FSSC 22000 draws a precise line between these two terms, set out in Appendix 1 of the Scheme:

Figure 2: Official FSSC 22000 definitions of food loss and food waste [Source: FSSC 22000 Scheme V6/V7, Appendix 1]

What’s In Scope — and What Isn’t

FSSC’s Guidance Document is explicit about the boundaries of Clause 2.5.16. These scope rules matter, because they determine exactly what your measurement programme should — and shouldn’t — include:

• Food only, not packaging: the weight of packaging material is excluded from FLW measurement. Edible packaging, however, is considered food.
• Pre-harvest wastage is excluded: farming falls outside the scope of the FSSC 22000 Scheme, so pre-harvest losses are not measured under 2.5.16.
• Both food and inedible parts are in scope: FLW includes food, ingredients, additives, drinks and pet food intended for consumption (human and animal), plus associated inedible parts removed from the food supply chain.
• Rescued and donated food is included: safe, wholesome food rescued and supplied to secondary markets — for example, donations to charities — falls within the scope of 2.5.16. This is a deliberate difference from the FLW Protocol’s own accounting standard, which excludes rescued/donated food from its FLW inventory total.

Following One Product Through the Chain

Take a tomato. It’s harvested, transported, processed, packed, distributed, placed on a shelf, and eventually purchased. At every one of those stages, product can be lost: hail damage on the farm (out of FSSC’s scope), a changeover on the factory floor, a temperature failure in storage, transport damage in distribution, or expired stock at retail.

This eBook focuses mainly on what happens inside the factory gates — receiving through to finished goods — because that’s where a certified site has the greatest ability to measure, manage, and demonstrate improvement, and it’s exactly where FSSC 22000 expects you to focus your Clause 2.5.16 programme.

3. The Food & Drink Material Hierarchy

FSSC’s own Guidance Document builds its implementation advice around the food waste hierarchy developed by the UN Food and Agriculture Organization (FAO). It ranks the possible destinations of food loss and waste from most to least preferable, and it’s the single most useful mental model for deciding what to do with any product that can’t be sold as intended.

Figure 3: The food and drink material hierarchy [Source: FAO, as adapted in the FSSC 22000 Guidance Document: Food Loss and Waste]

The intent behind Clause 2.5.16 is to move waste up this hierarchy wherever possible. If your organisation currently sends product to landfill or disposal, the Scheme expects you to investigate whether there’s a feasible way to move it up toward recovery, recycling, or — ideally — optimisation or prevention instead.

4. Where Losses Occur in Food Manufacturing

Losses don’t happen in one place. They accumulate quietly across every stage of the process — from the moment a truck arrives at the gate to the moment finished product leaves the warehouse. Understanding each stage is the foundation of any credible FLW programme, and it’s exactly the operational evidence an auditor will expect to see behind your Clause 2.5.16 policy.

5. The Six Root Causes Behind Food Loss & Waste

At first glance, rejected deliveries, expired stock, changeover losses, packaging errors and customer returns look like entirely different problems. In practice, when properly investigated, almost every loss traces back to one of the same six underlying causes.

Figure 4: The six recurring root causes of food loss and waste [Source: Entecom Webinar guidance]

This maps closely onto the causes and drivers FSSC’s own Guidance Document sets out stage-by-stage across the supply chain — for example, spillage and cosmetic damage during handling and storage, or errors in processing resulting in defects. Whichever framework you use, the underlying discipline is the same: don’t just record that a loss happened — investigate why.

This is genuinely good news. It means an organisation doesn’t need to solve hundreds of different waste problems — it needs to identify which of these six causes is driving the biggest losses, and focus improvement effort there.

6. Measuring Food Loss & Waste — Target, Measure, Act

Knowing that losses occur doesn’t improve anything on its own. The value comes from turning losses into information — and information into action. FSSC’s Guidance Document recommends a simple three-step process for building a food loss and waste strategy: Target, Measure, Act. It’s the clearest practical framework available for meeting Clause 2.5.16, and it underpins everything else in this section.

Figure 5: The FSSC 22000 Target-Measure-Act framework for a food loss and waste strategy [Source: FSSC 22000 Guidance Document: Food Loss and Waste]

Step 1 — Target

• Quantify your baseline: identify every type of FLW generated at each step of your process (procurement, processing, packing, storage, distribution), establish a time period, and calculate the current quantity for each type — in kilograms, litres, cost, or emissions, as appropriate.
• Investigate root causes: determine why the loss is happening before setting a target.
• Set objectives and targets: decide which types of FLW will be focus areas, and set both short-term (annual/quarterly) and long-term (5–10 year) targets — aligned with any government or industry targets where relevant.
• Define actions: assign responsibilities, resources and timeframes. Actions should aim to prevent FLW from occurring, rescue food for donation, or redistribute it to a higher destination on the material hierarchy.

Step 2 — Measure

• Monitor against baseline: define monitoring procedures to measure FLW against your baseline at regular intervals, using a methodology suitable to your operation.
• Track destination: monitor where FLW currently goes, and whether it’s moving up the material hierarchy over time.
• Evaluate results: determine whether each objective and target has been achieved.

Step 3 — Act

• If the target wasn’t met: investigate the cause and implement suitable corrective actions.
• If the target was met: still evaluate whether further reductions are possible, or whether a more sustainable destination could now be reached.

Documented information must be available to support the targets and objectives set, and the resulting measurement and monitoring. Review of FLW targets and objectives should be built into your management review process — this is also where Clause 2.5.16 connects directly to Clause 2.5.9, Measurable Objectives and KPIs (covered in Section 8.3).

What Good Measurement Looks Like

Figure 6: Example KPIs for a food loss and waste dashboard [Source: Entecom Webinar guidance]

7. New Requirements — FSSC 22000 Version 7, Clause 2.5.16

FSSC 22000 Part 2, Clause 2.5.16, Food Loss and Waste, applies to all food chain categories except Category I (food packaging manufacturing). The requirement was first introduced with Version 6 in 2023 and carries forward into Version 7.0. In addition to Clause 8 of ISO 22000:2018, the organisation shall:

1. a) Have a documented policy and objectives detailing the organisation’s strategy to reduce food loss and waste within their organisation and the related supply chain.
2. b) Have controls in place to manage products donated to not-for-profit organisations, employees, and other organisations, and ensure that these products are safe to consume.
3. c) Manage surplus products or by-products intended as animal feed/food to prevent contamination of these products.
4. d) Ensure these processes comply with the applicable legislation, are kept up to date, and do not have a negative impact on food safety.

Verbatim requirement text, FSSC 22000 Scheme Part 2, Clause 2.5.16 [Source: FSSC 22000 Guidance Document: Food Loss and Waste]

7.1 Managing Donated Products — Clause 2.5.16(b)

Where an organisation has surplus product, or product that doesn’t meet quality specifications, and intends to rescue and donate it to not-for-profit organisations such as charities and food banks, to employees, or to other organisations, it must implement suitable controls to keep that product safe for consumption.

• Controls must take applicable legislation into account and must not have a negative impact on food safety
• Maintain the products under correct storage conditions
• Maintain traceability of donated products
• If the product is customer-branded, obtain the customer’s agreement before donating it

7.2 Managing Surplus Products & By-Products — Clause 2.5.16(c)

Surplus products or by-products intended as animal feed or animal food must be managed to prevent contamination:

• Store surplus/by-product material separately from waste to prevent contamination
• Maintain traceability of these products
• Ensure the products comply with applicable legislation and are kept up to date
• If the surplus product is customer-branded, manage it in accordance with customer requirements

7.3  Food Safety Culture (2.5.8) & Measurable Objectives (2.5.9)

Clause 2.5.16 doesn’t sit in isolation. FSSC 22000 Version 7 continues to strengthen food safety and quality culture requirements, and food loss and waste is one of the clearest places this shows up in practice. Senior management must establish, implement and maintain culture objectives supported by a documented culture plan with targets, timelines and evidence, built around four minimum elements:

• Communication: how food safety and FLW information is shared across the organisation.
• Training: ensuring personnel understand why product losses matter, not just how to record them.
• Employee feedback and engagement: channels for personnel to raise concerns and report losses without fear of blame.
• Performance measurement: monitoring activities across all sections of the organisation that impact food safety and quality.

For measurable objectives (Clause 2.5.9), organisations are expected to establish measurable KPIs supported by trend data and regular review, include this analysis as an input to management review, include FLW within internal audit scope, and demonstrate continual improvement — not just maintenance of the status quo.

7.4  Category-Specific Guidance

FSSC’s Guidance Document sets out additional, category-specific expectations beyond the general 2.5.1–2.5.16 guidance for food and feed manufacturers:

• Category E — Catering & Food Service: effective inventory management (including correct ordering and stock control), training on recipe management, menu construction that reuses multi-use ingredients, seasonality planning, effective portion control, and customer education on FLW.
• Category FI — Retail, Wholesale & E-commerce: objectives should also aim to educate customers and build FLW awareness at the household level, e.g. through marketing and awareness campaigns.
• Category FII — Brokers & Traders: since these organisations don’t physically handle product, their FLW objectives should relate to their suppliers — for example, supporting suppliers to implement FLW strategies as part of supplier agreements.
• Category G — Transport & Storage: objectives should relate to maintaining product shelf life during transport and storage (preventing wastage), implementing FEFO/FIFO stock rotation, and minimising damage-related disposal by moving damaged product up the material hierarchy where it poses no food safety risk.
• Category K — Bio/Chemicals Production: must still meet 2.5.16(a) and (d); (b) and (c) may not apply depending on operations. Out-of-specification product should generally be downgraded to other technical grades rather than wasted, with alternative uses investigated before disposal.

8. Practical Improvement Ideas

The good news is that reducing food loss and waste doesn’t usually require major capital investment. More often, it’s about making lots of small improvements, consistently, and measuring whether they worked.

·      Receiving

Stop problems before they enter the factory. Better supplier approval processes, clearer specifications, and consistent temperature verification all help prevent downstream losses. Every rejected load is valuable information about supplier performance.

·      Production

This is usually where the biggest opportunity lies. Clear work instructions, efficient changeovers, and well-maintained prerequisite programmes all help reduce unnecessary losses. Ask every production manager: “Where do we lose the most product during a normal production day?”

·      Warehouse & Storage

Good warehouse management isn’t just about inventory — it’s about protecting product value. Better stock visibility, accurate inventory, and effective FIFO/FEFO all help ensure that perfectly good product reaches customers instead of becoming waste. FSSC’s guidance also recommends reviewing established shelf life periodically — a product that is still genuinely safe for consumption shouldn’t be discarded simply because its shelf life was set conservatively.

·      Downgrading & Alternative Markets

Where products don’t meet quality parameters against their finished product specification, look for alternative markets before writing the product off entirely — this directly reduces the volume moving down the material hierarchy toward disposal.

·      Culture

Food loss is as much a culture issue as a process issue. If employees understand why product losses matter, they’re far more likely to report, investigate and help prevent them — this is also your evidence base for Clause 2.5.8.

·      Management Engagement

Management sets the direction. If waste is only discussed during audits, nothing changes. If it’s reviewed regularly, trends are analysed, improvement actions are assigned, and successes are celebrated, reducing waste becomes part of the organisation’s culture rather than just another KPI.

9. Guidance for Internal Auditors

FSSC’s own Guidance Document sets out a non-exhaustive list of questions auditors use to assess Clause 2.5.16. Reviewing these before your next audit is one of the fastest ways to check whether your FLW programme is genuinely audit-ready:

• Has a policy and objectives, with measurable and time-bound targets, been established for food loss and waste?
• Have the objectives been met — and if not, were suitable actions taken? (This wouldn’t apply in the first year of establishing the policy and objectives.)
• Does the organisation donate products, and if so, are there controls in place — including controls to ensure the food safety of donated products?
• Does the organisation produce surplus products or by-products intended as animal feed/food, and if so, are there controls in place to prevent contamination of these products?
• Are legal requirements and food safety taken into consideration when establishing the policy and objectives, including any controls established?

Auditors will also verify that the necessary documented information is available to support all of the above — not just that a policy exists, but that it’s backed by evidence of measurement, review, and action.

10. Your Food Loss & Waste Transition Roadmap

Approach your Clause 2.5.16 programme using FSSC’s own Target-Measure-Act framework, phased into four practical stages. The goal isn’t to build an entirely new system — it’s to capture what’s already happening on your site, and turn it into documented, measurable evidence.

Figure 7: Four-phase roadmap to a Clause 2.5.16-ready FLW programme [Based on FSSC 22000 Guidance Document: Food Loss and Waste, and Entecom Webinar guidance]

Phase 1 — Assess

• Walk your process, from receiving to finished goods, and observe where product is lost
• Establish the scope of your FLW inventory — food chain steps, material types, and destinations within your control
• Review your current FLW policy (if one exists) against Clause 2.5.16(a)–(d)

Phase 2 — Target

• Quantify a baseline for each FLW type you plan to focus on
• Set short-term (annual/quarterly) and long-term (5–10 year) measurable targets
• Define actions: prevent, rescue for donation, or redistribute up the material hierarchy

Phase 3 — Measure

• Start measuring one source of loss you’re not currently monitoring
• Categorise losses by reason, not just quantity (expiry, damage, pest, changeover, etc.)
• Track destination — is FLW moving up the hierarchy over time?

Phase 4 — Act & Review

• Where targets aren’t met, investigate causes and implement corrective actions
• Include FLW trend data and improvement actions as a standing management review item
• Include FLW policy, targets and evidence within internal audit scope
• Share results with your team — because the objective isn’t simply to collect data, it’s to create conversations, identify opportunities, and continuously improve

11. Implementation Checklist

Use this checklist to plan and track your Clause 2.5.16 programme. Items are prioritised by audit impact and implementation effort — HIGH items should be addressed before your next audit; MED items within 3–6 months; LOW items are ongoing or longer-term.

Figure 8: FSSC 22000 food loss and waste implementation checklist [Source: FSSC 22000 Guidance Document: Food Loss and Waste; FSSC 22000 V7.0; Entecom Webinar guidance]

REFERENCES

This eBook was produced by Entecom based on the FSSC 22000 Guidance Document: Food Loss and Waste, the FSSC 22000 Scheme (Version 6 and Version 7.0), the GFSI Benchmarking Requirements Version 2024, and the Entecom Industry Support Webinar Series. For consulting support, system implementation assistance, or to learn more about Entecom’s cloud-based food safety management platform, please visit www.entecom.co.za or contact us on info@entecom.co.za