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CCP decision tree

Updated 2026-07-12 · Reviewed by: Redazione ce85204 — revisione editoriale assistita da AI (2026-07-12)

The decision tree is the Codex Alimentarius tool (CXC 1-1969, rev. 2020) for establishing whether a step is a CCP through a sequence of yes/no questions. It implements the second HACCP principle under Article 5(2) of Regulation (EC) 852/2004.

At a glance

  • The decision tree helps establish, step by step, whether a point in the process is a CCP.
  • It is defined by the Codex Alimentarius in the General Principles of Food Hygiene CXC 1-1969 (rev. 2020).
  • It consists of a sequence of yes/no questions applied to each significant hazard.
  • It implements the second of the seven HACCP principles Article 5(2) of Regulation (EC) No 852/2004.
  • It is not legally mandatory: it is a tool; Commission Notice 2022/C 355/01 also proposes simplified versions for small businesses.

Commentary

What it is for

Identifying CCPs is the most delicate step of hazard analysis: overstating them makes the plan unmanageable, understating them leaves hazards uncontrolled. The decision tree is the tool the Codex Alimentarius devised to make this choice transparent and repeatable. It is applied after completing hazard analysis and identifying control measures (step 6 of the Codex's twelve), and answers a single question for each significant hazard at each step: is this step a critical control point?

The Codex sequence of questions

The Codex decision diagram (CXC 1-1969, rev. 2020) frames the assessment as a series of binary questions. In substance:

  1. Does a control measure for the hazard exist at this step or elsewhere? If not, and control is necessary for safety, the step, process or product must be modified.
  2. Is the step specifically designed to eliminate the hazard or reduce it to an acceptable level? If yes, the step is a CCP.
  3. Could contamination occur or increase to unacceptable levels? This determines whether the hazard is genuinely relevant at that step.
  4. Will a subsequent step eliminate the hazard or reduce it to an acceptable level? If yes, the step under examination is not a CCP (the essential control is downstream); if no, it is a CCP.

The underlying logic is that of the essentiality of control, consistent with the Article 5 definition, which refers to steps at which control "is essential" Article 5(2) of Regulation (EC) No 852/2004.

The simplified tree

The classic tree has often been criticised for being hard to apply in small businesses and for the risk of forced answers. For this reason Commission Notice 2022/C 355/01 and many sector guides propose simplified approaches: in catering and retail activities, rather than subjecting every step to the full tree, one starts from the premise that prerequisites and good hygiene practices control most hazards, reserving CCP identification for the few genuinely decisive steps (typically cooking, cooling and temperature-controlled storage). The simplified tree thus reduces the number of questions and anchors the decision to operational common sense, without giving up traceability of the choice.

The decision tree is not required by Regulation (EC) 852/2004: the Regulation requires procedures "based on the HACCP principles" Article 5(1) of Regulation (EC) No 852/2004 and CCP identification as a principle Article 5(2) of Regulation (EC) No 852/2004, but prescribes no specific method. The tree is therefore a recommended tool, not a formal obligation: what the competent authority verifies is that the choice of CCPs is justified and consistent with the hazard analysis. An interactive version is available among the site's tools (CCP decision tree).

Common errors

  • Applying the tree before doing the hazard analysis. The tree presupposes hazards and control measures already identified: using it earlier produces arbitrary answers. It is the second principle, not the first Article 5(2) of Regulation (EC) No 852/2004.
  • Forcing every step to become a CCP. If a hazard is governed by prerequisites or an OPRP, the step is not a CCP: the tree exists precisely to avoid proliferation.
  • Treating the tree as a legal obligation. It is not: Regulation (EC) 852/2004 does not cite it Article 5(1) of Regulation (EC) No 852/2004. It is a Codex tool, useful but replaceable by equivalent, justified methods.

Frequently asked questions

What is the HACCP decision tree?

It is a Codex Alimentarius logic tool that, through a sequence of yes/no questions, helps establish whether a process step is a CCP. It implements the second HACCP principle Article 5(2) of Regulation (EC) No 852/2004.

Where is the official decision tree found?

In the Codex Alimentarius document General Principles of Food Hygiene CXC 1-1969, in the 2020 revision, which contains the decision diagram for identifying CCPs.

Is the decision tree mandatory?

No. Regulation (EC) 852/2004 requires procedures based on HACCP principles Article 5(1) of Regulation (EC) No 852/2004 but does not impose the tree: it is a tool recommended by the Codex, replaceable by equivalent methods provided the choice of CCPs is justified.

How many questions does the decision tree have?

The classic Codex tree is framed around four main questions applied to each significant hazard. The simplified versions for small businesses reduce the number of questions, anchoring the decision to the few genuinely decisive steps.

How does the simplified tree work?

It starts from the premise that prerequisites control most hazards and limits CCP identification to the decisive steps (cooking, cooling, temperature-controlled storage). This is the approach encouraged by Commission Notice 2022/C 355/01 for simple activities.

Do I need software for the decision tree?

No, it is not necessary: the tree can be applied on paper. A guided tool can, however, reduce errors. The site's tools section is set to include an interactive CCP decision tree.

Sources

Drafting and review

ce85204 editorial team. Draft generated with AI from primary sources; editorial review AI-assisted (see methodology).