Information sheet 64: how do you apply these guidelines in practice?
27 February 2025
Information sheet 64: how do you apply these guidelines in practice?
If you purchase products as raw materials or as commercial products, you are responsible for the safety of these products. HACCP procedures enable you to manage the hazards that may arise. Information sheet 64 is a guide that describes a number of control options that you can apply to manage relevant hazards associated with the purchase of food and raw materials. How does this work in practice and how do you comply with the guidelines?
Information sheet 64 has been in existence since November 2022 and is a combination of the previous version, Information sheet 64, and the old Information sheet 65. The focus is on controlling relevant hazards associated with the purchase of food (including raw materials) within the framework of HACCP. A new version was published in April 2024. Its content is no different from the previous version, but it attempts to provide more clarity with regard to definitions such as “scope” and “sectoral monitoring programmes”.
Legislation or guidelines?
Information sheet 64 is not legislation, but it does have a legal basis in General Food Law and Regulation (EC) No. 852/2004, Article 14, which states: ‘You shall not place an unsafe product on the market.’ The document describes a number of control options that you, as a food business operator, can apply to manage the relevant hazards associated with the purchase of food and raw materials.
Identify potential hazards
In an HACCP plan, it is important to identify and name all hazards, looking beyond your own company and processes. Also, make sure to take into account situations that may arise in the future.
A hazard that does not currently apply to your raw material group may have a significant impact in the future. It is good to be prepared for this and to keep an eye on potential hazards throughout the entire raw material sector. Potential incidents/recalls that are currently occurring in another country or continent may eventually affect your raw material due to climate change or shifts in industries.
To identify all possible hazards, use the HACCP method: hazard identification. This allows you to divide raw materials into groups, for example, to identify the hazards. The control of the relevant hazards identified for each raw material in your company must be demonstrable. Information sheet 64 requires a decision on whether a hazard is a relevant hazard. Therefore, explain how you have determined the risk, including the motivation for the likelihood and severity of the defined hazards based on multiple sources. Record everything in the HACCP plan so that you can always find and discuss the motivation and substantiation if requested.
Please note: essential control is certainly required for hazards that have a legal standard. Examples include microbiological hazards specified for specific raw materials in Regulation (EC) No. 2073/2005 or the chemical hazards specified in Regulation (EC) No. 2023/915.
Tip: With the Normec Foodcare Knowledge Centre subscription, you have access to the Risk Safety Sheets and HACCP risk sheets available for hazard and risk analysis. These also list the sources that you can include as supporting documentation.
Manage relevant hazards
Information sheet 64 provides several options for controlling relevant hazards by the Dutch Food and Consumer Product Safety Authority (NVWA). These are possibilities. Every company is different, so consider which options are best for your company and situation.
In addition, you are free to choose from multiple options or even implement your own control measures that are not mentioned in the information sheet. It is always important that you can demonstrate and justify that the chosen option contributes to the purchase of safe raw materials and the control of identified hazards in the supply chain.
Supplier control
Of course, ensuring food safety is primarily the responsibility of the producer of the raw materials. However, as a company, you are also obliged to control your suppliers. Information sheet 64 therefore focuses specifically on supplier management and raw material analyses.
Supplier information
During the purchasing process, it is important to request the necessary information from suppliers. This includes information about chain assurance, quality certificates, including GFSI-recognised standards, and hazard control by the supplier itself.
Data can be requested using a questionnaire or by conducting an audit. It is important to gain a good understanding of how hazards are controlled at every step of the chain. This requires open communication between the various parties.
Analyses
As described in Appendix 2 of the information sheet, requesting analysis results when purchasing raw materials can be a control measure. It is not only important to verify the results against the raw material specifications and purchase agreements, but also against the applicable standards and legislation.
Furthermore, the analysed parameters should provide information about the hazards identified for these raw materials in the HACCP risk analysis (gira). These analyses must be carried out according to recognised (accredited) methods. So be sure to check the method used.
Pitfalls
The risk of a particular hazard is determined by the likelihood of the hazard occurring and the severity of the hazard. If the probability is estimated to be too low, the risk will also be low. This means that too few or no control measures may be implemented for a hazard that could still occur. Company-specific control measures are also often incorrectly taken into account. For example, when goods are heated further in the process.
When determining the control measures, it is also necessary to ensure that they keep the identified hazards under control. It is therefore important to thoroughly validate these control measures. It is better to have a limited number of effective control measures than a whole host of measures that involve a lot of work but yield no results.
Get started with Information Sheet 64
How you comply with the guidelines of Information Sheet 64 differs per company and situation. Our Quality Assurance advisors will be happy to work with you to assess how you currently control raw material hazards and what adjustments and actions are needed.