Factories / OEM

GMP vs HACCP: what a Thai food plant needs first

9 min read · Updated 27 Oct 2026

GMP vs HACCP in one paragraph

GMP vs HACCP is one of the first questions a new food plant asks. GMP (Good Manufacturing Practice) is the baseline for the whole site: buildings, equipment, process control, sanitation and staff hygiene. HACCP (Hazard Analysis and Critical Control Point) is a method for analysing the hazards at each step of making one product, then choosing the points that must be tightly controlled to prevent, reduce or remove those hazards.

In Thailand the order is clear. Food produced for sale must follow Good Manufacturing Practice under Ministry of Public Health Notification No. 420 B.E. 2563 (2020), which is mandatory. The word HACCP does not appear in that notification. HACCP usually arrives as an extra standard that buyers, export markets or certification bodies ask for on top of the legal baseline.

This guide explains how the two systems differ, where Thai rules do mention HACCP, what GHP means in Codex documents, which standards the Thai FDA regards as equivalent to GMP 420, and how a plant can sequence the work. For a clause-by-clause view of GMP 420, read GMP 420 requirements and audit criteria.

What Thai law says: GMP 420 is mandatory, HACCP is not named

Clause 2 of Notification No. 420 requires food produced for sale anywhere to follow the production methods, equipment and storage rules in its annex, with a few exceptions: outlets cooking food for immediate consumption (unless they make label-required or quality-standard food using machinery of five horsepower or more, or seven or more workers), stalls in public places, edible salt producers, and certain fresh fruit and vegetable packing sites already covered by their own notification.

The annex has two parts. Part 1, the basic requirements, applies to every food plant and has five categories: location and buildings, equipment and machinery, production process control, sanitation, and personal hygiene. Part 2, the specific requirements, adds rules for three higher-risk groups: drinking water in sealed containers, natural mineral water and filtered ice; liquid pasteurised milk; and low-acid and acidified foods in hermetically sealed containers.

HACCP thinking already inside GMP 420

Although the notification never says HACCP, several clauses use the same logic of finding hazards and controlling key points:

• The stated purpose of the basic requirements is to prevent contamination and to reduce or remove physical, chemical and microbiological hazards at every production step.
• Clause 3.4 requires control of the microbial reduction step, regular checks and records.
• Clause 3.5 says that where there is no microbial reduction step, such as mixing, repacking or trimming fresh food, contamination must be strictly controlled throughout the process according to the risk of that food.
• Clause 3.8 requires traceability data, and clause 3.10 requires distribution records and a recall method.
• The specific requirements for low-acid and acidified foods refer to critical factors, require a written Scheduled Process, and require aseptic systems to have a process flow diagram showing the critical factors to control.

The practical conclusion: a plant that fully meets GMP 420 already has much of the data and record-keeping discipline HACCP needs. But having GMP does not mean having a HACCP plan, because HACCP requires a separate, product-specific hazard analysis and set of critical control points.

HACCP and GMP difference

The simplest way to remember the difference: GMP looks after the production environment of the whole plant, while HACCP looks after the specific hazards of each product along its process. They do not compete; they stack. In Codex guidance, HACCP sits on top of good hygiene practice. If the base is weak, for example rooms that are hard to clean, no pest control or staff who skip hand washing, the HACCP plan ends up carrying too many control points to work in practice.

• Scope: GMP covers the whole site; HACCP is written per product or per group of similar processes.
• Main question: GMP asks whether the plant is clean, orderly and under control; HACCP asks which hazards matter and at which step they must be controlled.
• Documents: GMP relies on work procedures and daily records such as cleaning logs and staff health checks; HACCP relies on a hazard analysis table, the HACCP plan and monitoring records for each critical control point.
• Legal status in Thailand: GMP 420 is mandatory for food produced for sale. GMP 420 contains no general HACCP requirement, although some topic-specific Thai rules accept HACCP as one of several forms of evidence.

The table below sums up the differences plants are most often asked about during audits or customer supplier approval.

What is HACCP: the seven principles

The HACCP principles used around the world come from the Codex Alimentarius Commission. This section summarises them at a general level for orientation; it is not a Thai legal requirement. Before the seven principles, teams usually complete five preparatory steps: form a HACCP team with people from production, quality and maintenance; describe the product; state its intended use and consumers; draw a process flow diagram; and walk the floor to confirm the diagram matches reality.

1. Conduct a hazard analysis: list the biological, chemical and physical hazards at each step and decide which are significant.
2. Determine critical control points (CCPs): steps where loss of control would let a hazard reach the consumer, such as heating or metal detection.
3. Set critical limits: the values that separate acceptable from unacceptable, such as a minimum time and temperature.
4. Set up monitoring: who measures what, how often, and where it is recorded.
5. Define corrective actions: what happens to product made while a limit was exceeded, and how the cause is fixed.
6. Verify: confirm the plan works, for example by reviewing records, calibrating instruments and testing samples.
7. Keep documents and records: evidence for every step, so the system can be checked later.

Compared with GMP 420, much of the groundwork is already required: measuring equipment must be calibrated at least once a year (clause 2.8), records must be kept for at least one year after the shelf life shown on the label (clause 3.12), and an internal audit must be done at least once a year (clause 3.13). What HACCP adds is a reasoned decision about which points are critical, with limits and corrective actions written in advance rather than improvised after a problem.

GHP vs GMP: the Codex term and standards equivalent to GMP 420

GHP stands for Good Hygiene Practices, the term Codex uses for the basic hygiene rules of food production. Its content is close to what Thailand calls GMP in the sense of the basic requirements. The Codex text cited most often is CXC 1-1969, which covers both GHPs and HACCP in one document, which is why people searching for GHP and GMP usually meet both terms together.

The Thai FDA publishes a guidance list of example food production standards that are equivalent to or not lower than the annex of Notification No. 420, last updated on 17 December 2025. Part 1, which maps to the basic requirements, gives international examples such as:

• Codex GHPs and HACCP (CXC 1-1969)
• ISO 22000:2018
• BRC Global Standard for Food Safety, IFS, SQF and FSSC 22000
• National laws or standards of individual countries, for example the European Union, the United States, Japan, Korea, China, Taiwan and some ASEAN members

A note in the list says that standards not on it are also treated as meeting Notification No. 420 if their requirements are equivalent or stricter, and that the list is guidance, not the notification itself. The three specific-requirement groups have their own lists, such as CAC/RCP 48-2001 for drinking water, CAC/RCP 57-2004 for pasteurised milk, and CAC/RCP 23-1979 and CAC/RCP 40-1993 for low-acid and acidified foods.

Who uses this list most

Importers come first. Clause 6 of Notification No. 420 requires food importers to hold certification showing the foreign producer meets a standard equivalent to or not lower than the annex, so foreign HACCP or GHPs certificates are commonly used as that evidence. Second are Thai plants that already hold an international certificate and want to know whether it covers the Thai basic requirements. In both cases, check that the certificate scope matches the actual food type and production site.

GMP and HACCP standards: what a plant needs first

For a food plant in Thailand, the safest order is to complete what the law requires first, then add what the market asks for. Most plants can follow four stages:

1. Licence and GMP 420: the site must meet all five basic categories, plus the specific requirements if it makes one of the three high-risk groups. Under the Thai FDA notification on auditing food premises, a site passes when every category scores at least 60 percent and no major defect is found.
2. Working documents and records: production, cleaning and calibration records, finished-product analysis at least once a year, and traceability data.
3. A GMP certificate from a certification body: if customers want to see a certificate, the Thai FDA notification on issuing food production system certificates (2021) has plants apply to a certification body listed with the Thai FDA. The certificate is valid for three years from signature, with one surveillance audit a year, and is marked Excellence Level when the total score across all categories is at least 85 percent.
4. HACCP when buyers or export markets require it: start with exported or higher-risk product lines and build on the data the GMP system already produces.

Where Thai rules do name HACCP

Although GMP 420 does not use the term, documents in our law archive name HACCP explicitly. The first example is the import of food at risk from bovine spongiform encephalopathy under Ministry of Public Health Notification No. 459 (2025): importers show a certificate that the production site runs one of several quality assurance systems, namely Codex HACCP, the latest ISO 22000, PIC/S GMP, or another international system the Thai FDA has accepted as equivalent, and the Thai FDA has published five standards it regards as equivalent to HACCP. The second example is that inspection and certification bodies seeking listing with the Thai FDA must be accredited in the Codex GMP/HACCP field or an equivalent.

Not sure how ready your site is? Send us photos and details of the premises through our contact page.

GMP and HACCP claims on labels: what is allowed

Once certified, many brands want a GMP or HACCP logo on the pack. The Thai FDA notification on displaying statements or marks of food production system certification, in force since 2021, sets these rules:

• Management system certifications, such as GMP under the Ministry notification, GHPs, HACCP, ISO 22000, BRC and FSSC 22000, may not appear as a mark or logo on the label. They may be shown as a text statement only.
• The statement must not suggest that the product itself is certified, and it must name the production site, the type of standard and the certification body that issued the certificate.
• It may only be used for food made at a site certified by the responsible government agency, a government-recognised body, or a certification body accredited by an IAF member.
• It must not imply a wider scope than the certificate covers. A valid certificate covering that food must be available for checking, and if the certificate is suspended, withdrawn or not renewed, the label must stop being used immediately.

The Thai FDA guidance that explains this notification adds that FSSC 22000 cannot be shown on food labels at all, because the standard itself forbids certification marks and statements on product labels. The GMP certification mark printed on certificates from listed certification bodies may not be placed on food labels either.

An example of a compliant statement: produced by (site name), certified to HACCP by (certification body). Before printing, confirm the certificate scope covers that exact product, and track the certificate expiry date, because pre-printed labels cannot be used once the certificate lapses.

Preparing a plant for both GMP and HACCP

A plant running both systems does not need two parallel sets of paperwork. Approaches that work well in small and mid-sized plants:

• Self-assess with the real audit forms: GMP 420 audits use form TS.2 (63) for the basic requirements plus specific forms by product group. Close major defects first, because a single one fails the audit even with a high total score.
• Draw one process flow diagram: use it both to show the flow of people, materials and product for GMP and as the starting point of the HACCP hazard analysis.
• Link the records: time and temperature records for the microbial reduction step, already required under GMP, become CCP monitoring records once critical limits and responsibilities are defined.
• Train the floor team: personal hygiene under GMP, and an understanding of why a critical limit must never be missed. Whoever takes the reading must know what to do the moment it is out of range.
• Review after every change: a new recipe, raw material, machine or supplier means revisiting the hazard analysis. The annual internal audit required by clause 3.13 is a good moment to review the HACCP plan as well.

Choosing a contract manufacturer? See the questions to ask in What is GMP. Planning exports? Start with exporting processed food from Thailand. TIBD can help design your system through our factory setup service and train your team on GMP and HACCP through our training courses.

Sources

1. MOPH Notification No. 420 B.E. 2563 (2020) on production methods, equipment and food storage · Open source · Search our archive
2. Thai FDA notification on auditing food premises against No. 420 · Open source · Search our archive
3. Thai FDA list of example food production standards equivalent to the annex of Notification No. 420 · Open source · Search our archive
4. Thai FDA notification on issuing food production system certificates under legal criteria B.E. 2564 (2021) · Open source · Search our archive
5. Thai FDA notification on displaying statements or marks of food production system certification · Open source · Search our archive
6. Thai FDA guidance on displaying food production system certification on labels · Open source · Search our archive
7. List of food production standards equivalent to HACCP or ISO 22000:2018 · Open source · Search our archive
8. MOPH notification on criteria for listing inspection and certification bodies for food establishments (2018) · Open source · Search our archive

This article is for general information. It is not a Thai FDA ruling or legal advice, and rules change — check the latest notification or ask an expert before filing or producing.

Related articles

Factories / OEMGetting GMP for your plant: from documents to inspection dayGMP certification steps for a Thai food plant: self-assessment on the audit forms, records, the audit request, what inspectors check, and certificates.10 min read · Updated 9 Nov 2026Factories / OEMGMP 420 explained: key requirements, the inspection forms and how audits are scoredThailand's GMP 420 for food plants: the five basic categories, specific requirements, the TS.1–TS.5 audit forms, scoring, pass criteria and major defects.9 min read · Updated 26 Oct 2026Factories / OEMWhat is GMP, and why Thai food and cosmetic plants need itWhat GMP means in Thailand: food GMP No. 420 and cosmetic premises rules, who must comply, how audits are scored, and what importers must hold.9 min read · Updated 26 Oct 2026