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CCP decision tree: the Codex four questions for critical control points

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

The Codex Alimentarius decision tree (CXC 1-1969, rev. 2020) identifies critical control points through four sequential questions (Q1-Q4). It is a teaching aid, not binding: Article 5 of Reg. (EC) 852/2004 requires identifying CCPs, not using the tree.

The decision tree is the traditional tool for deciding whether a process step is a critical control point (CCP). Developed within Codex Alimentarius and set out in an appendix to document CXC 1-1969 (General Principles of Food Hygiene, rev. 2020), it is a sequence of four questions applied to each significant hazard at each step. This page reproduces its logic, interactively below and in numbered text form further down, with outcomes and two worked examples. It is a teaching aid to support reasoning, not a legal requirement.

CCP decision tree

Q1. Do preventive control measures for the identified hazard exist at this step (or later steps)?

Educational tool based on the Codex Alimentarius decision tree (CXC 1-1969, rev. 2020). It does not replace the hazard analysis performed by the HACCP team on the actual process.

At a glance

  • Article 5 of Reg. (EC) No 852/2004 requires identifying critical control points Article 5(2) of Regulation (EC) No 852/2004, not the use of a specific method.
  • The Codex CXC 1-1969 decision tree is a supporting tool, applied after the hazard analysis and after the prerequisites are set.
  • The four questions (Q1-Q4) lead to three outcomes: the step is a CCP, it is not a CCP, or the process must be modified.
  • The tree is applied to each significant hazard at each step, not to the step as a whole.
  • Not every step has a CCP: where the hazard is controlled by good hygiene practice, the Regulation's flexibility allows not forcing one.

Commentary

Before the tree: hazard analysis and prerequisites

The tree applies only after describing the product and process, carrying out the hazard analysis and identifying the control measures Article 5(2) of Regulation (EC) No 852/2004. Hazards already controlled by prerequisites — cleaning, personal hygiene, the basic cold chain — do not go through the tree: the tree distinguishes CCPs from OPRPs and prerequisite measures for hazards that remain significant after PRPs. The logic is that of the decision tree as a technical concept.

The four questions

Q1 — Do control measures exist for the hazard at this step? If yes, go to Q2. If no, ask whether control at that step is necessary for safety. If control is necessary but absent, the process or product must be modified to introduce a control measure (outcome: modify the process). If control at that step is not necessary, the step is not a CCP.

Q2 — Is the step specifically designed to eliminate or reduce the hazard to an acceptable level? If yes, the step is a CCP. If no, go to Q3.

Q3 — Could contamination occur or increase to unacceptable levels? If yes, go to Q4. If no, the step is not a CCP.

Q4 — Will a subsequent step eliminate the hazard or reduce it to an acceptable level? If yes, the current step is not a CCP (control rests with the later step, which will itself be assessed). If no, the current step is a CCP.

Example 1: cooking hamburgers

Significant hazard: survival of pathogens (e.g. E. coli O157, Salmonella) in minced meat. Q1: is there a control measure? Yes, cooking. Q2: is cooking designed to reduce the hazard to an acceptable level? Yes. Outcome: cooking is a CCP, with a measurable critical limit (core temperature, e.g. 70 °C for an adequate time) and documented monitoring Article 5(2) of Regulation (EC) No 852/2004.

Example 2: chilled storage

Hazard: growth of pathogens in a refrigerated product. Q1: is there a control measure? Yes, maintaining the cold chain. Q2: is storage designed to eliminate or reduce the hazard? No, it keeps it under control but does not eliminate it. Q3: could contamination or growth increase to unacceptable levels? Yes, if the temperature is not compliant. Q4: will a subsequent step eliminate the hazard? If adequate cooking follows, yes, and storage is not a CCP (typically an OPRP or a prerequisite). If the product is ready-to-eat with no further treatment, no, and storage becomes a CCP with a temperature limit Annex II, Chapter IX, point 5 of Regulation (EC) No 852/2004.

Caveat: a teaching aid, not an obligation

In our view the tree should be used with judgement. Codex itself, in the 2020 revision, warns that the tree is a supporting tool and that applying it mechanically can mislead: different steps may control the same hazard, and not every question fits every process. The Regulation does not require the tree: it requires identifying CCPs by an appropriate method Article 5(2) of Regulation (EC) No 852/2004. For simple businesses, the Commission notice on food safety management systems recognises that there are often no CCPs and that prerequisites are enough: see flexibility for small businesses and the Article 5 page.

Common errors

  • Applying the tree to the step rather than the hazard. A step can have several significant hazards: the tree must be run for each, or CCPs are lost or created needlessly Article 5(2) of Regulation (EC) No 852/2004.
  • Turning every prerequisite into a CCP. Cleaning, personal hygiene and maintenance are prerequisites: multiplying CCPs makes the plan unmanageable and diverts attention from real hazards.
  • Treating the tree as a legal requirement. It is not: it is a Codex tool. The obligation is to identify CCPs Article 5(2) of Regulation (EC) No 852/2004, by any appropriate method.

Frequently asked questions

Is the decision tree mandatory?

No. Article 5 requires identifying critical control points Article 5(2) of Regulation (EC) No 852/2004, but prescribes no method. The Codex CXC 1-1969 tree is a widely used supporting tool, not an obligation.

Is cooking always a CCP?

Often yes, when it is the step designed to reduce pathogens to an acceptable level and has a measurable critical limit (temperature and time) Article 5(2) of Regulation (EC) No 852/2004. But it depends on the product and process: the tree is applied to the specific hazard.

Is chilled storage a CCP?

It depends. If a later step (e.g. cooking) eliminates the hazard, it is usually a prerequisite or an OPRP; if the product is ready-to-eat, maintaining the cold chain can be a CCP with a temperature limit Annex II, Chapter IX, point 5 of Regulation (EC) No 852/2004.

What is the difference between a CCP and an OPRP?

A CCP has a measurable critical limit and point monitoring; an OPRP is an essential control measure without a measurable critical limit in the same sense. The tree helps tell them apart after the hazard analysis.

Is a small business with no CCP non-compliant?

No. The Regulation and the Commission guidance recognise that some businesses identify no CCPs and that well-managed prerequisites are enough Article 5(2) of Regulation (EC) No 852/2004. A hazard analysis and proportionate documentation are still required. See flexibility for small businesses.

Sources

Drafting and review

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