Regulatory Requirements as Control Measures: A HACCP-Based Model for Food Safety Compliance in the EU

Ensuring food safety in the European Union requires food business operators (FBOs) to apply structured, risk-based systems that respond to a wide range of regulatory requirements. Operational Prerequisite Programs (OPRPs), as part of Hazard Analysis and Critical Control Point (HACCP) plans, offer a practical means of managing significant food safety hazards that are not addressed at Critical Control Points (CCPs). This perspective article discusses how regulatory expectations related to hygiene, traceability, allergens, chemical contaminants, and food contact materials can be translated into effective OPRPs. Emphasis is placed on how these measures can be implemented by small and medium-sized enterprises (SMEs), which often face challenges related to technical capacity, documentation, and auditing. The article highlights examples of OPRPs linked to sanitation, supplier control, production procedures monitoring, packaging safety, and water quality, and considers their role in supporting both compliance and system improvement. By aligning operational controls with compliance obligations through OPRPs, FBOs can enhance transparency, audit readiness, and consumer confidence. This perspective provides a structured approach for integrating regulatory compliance into food safety management systems in a way that is practical, scalable, and adaptable to ongoing changes in the regulatory environment.