SQF Core Clauses: The Essential 2027 Guide to All 11

SQF core clauses are the 11 elements of the SQF Food Safety Code: Food Manufacturing, Edition 10 where a non-conformance costs you more points. They are new in Edition 10, and they change the arithmetic of an audit: a minor against a Core Clause costs two points instead of one, and a major costs seven instead of five.

This post lists the 11 SQF core clauses, explains how the heavier deductions work, and sets out what an auditor will ask to see in each one. The evidence lists follow the Edition 10 requirements as we read them; they are our summaries, so check the Code itself for the full text.

What SQF core clauses are

SQFI’s Edition 10 glossary treats Core Clauses as the foundations of a sound food safety management system, and weights them more heavily in scoring because they do so much to prevent food safety failures. Part A (A2:8 and A2:19) puts that weighting into the audit rules.

Here are the 11, with their mandatory status:

Core and mandatory are two different lists. Mandatory elements can never be reported as not applicable. Core Clauses are about scoring weight. Several mandatory elements, such as document control (2.2.2), product release (2.4.7) and internal audits (2.5.4), are not Core Clauses. Two Core Clauses sit in Module 11, which has no mandatory flags at all, although any clause you mark not applicable still needs a written justification or risk assessment.

Why findings against SQF core clauses cost more

The Edition 10 score is 100 minus deductions (A2:19):

A score of 80 or more is Certified; 70 to 79 is Certified with Surveillance, which adds a six-month surveillance audit. Now take one set of findings and move it around: four minors, two majors and six more minors.

• All against ordinary clauses: 4 + 10 + 6 = 20 points. Score 80, Certified.
• The first four minors and both majors against Core Clauses: 8 + 14 + 6 = 28 points. Score 72, Certified with Surveillance.

Same number of findings, same grades, a different rating and an extra audit. That is why SQF core clauses deserve more of your internal audit time than their share of the Code would suggest. Our SQF audit scoring guide works through more examples, including what happens below 70.

What auditors look for in each of the SQF core clauses

2.1.1 Management Responsibility

The auditor will want a food safety policy signed by senior site management, kept current and communicated in languages staff understand; evidence of a positive food safety culture; the new food safety culture assessment plan (2.1.1.3) with results and actions; food safety objectives and performance measures; a reporting structure that names backups for key roles; and a primary and substitute SQF Practitioner with the right training and authority. Interviews with floor staff test whether the culture on paper matches the culture on the line.

2.1.2 Management Review

Two things: an annual review of the whole SQF System, and updates to site management at least monthly. The annual review should show its inputs, such as changes to documents, results of the annual tests, trends in audit findings, complaints and pest activity, culture plan progress, regulatory matters and open actions. The monthly updates should cover issues like CCP deviations, corrective actions, audit results and complaints. A review with no actions recorded is a weak review.

2.1.3 Complaint Management

A documented process with named owners for logging, investigating and closing food safety complaints, whether they come from a customer, a consumer or a regulator, including complaints about products made by co-manufacturers. The auditor will pick complaints from the log and follow them to closure, then ask to see your trend analysis and the root cause investigation behind any adverse trend or serious incident.

2.3.4 Approved Supplier Program

A program covering selection, evaluation, approval and ongoing monitoring of suppliers, including emergency suppliers and suppliers under common ownership. Auditors check that approval considers risk, specifications and the supplier’s own food safety controls, that monitoring frequency is defined, and that supplier audits are scheduled by risk and done by people who understand the applicable requirements. A quick self-test: pick a delivered material and trace it back to an approved supplier and a current specification.

2.4.3 Food Safety Plan

The largest Core Clause, with 18 requirements. The plan follows the current Codex General Principles of Food Hygiene: a multidisciplinary team with a HACCP-trained leader, a defined scope, product descriptions, intended use, a verified flow diagram, a hazard analysis with a documented method for judging significance, control measures, CCPs with validated critical limits reviewed at least annually, monitoring, deviation and verification procedures, and records. Where local regulation prescribes its own method, such as US preventive controls, the plan has to meet both. Our HACCP plan guide covers the build.

2.4.8 Environmental Monitoring

A risk-based assessment that sets the level of monitoring needed (2.4.8.1, mandatory for every site), evaluated at least annually. Then a documented program: responsibilities, target pathogens or indicator organisms based on the hazard analysis, sample numbers, timing, locations and rotation, acceptance criteria and the response to poor results. Results must be trended, and unsatisfactory results or trends need root cause analysis and corrective action. See our SQF environmental monitoring guide.

2.5.3 Corrections, and Corrective and Preventative Action

A documented method for investigating and resolving problems from many sources: critical limit deviations, complaints, audit and inspection findings, non-conforming product and equipment, failed annual tests, withdrawals and recalls, regulatory infractions and negative trends. Auditors look for a defined root cause method, corrective and preventive actions, a check that the actions worked, and communication of results. Because every other finding flows through this element, a weak CAPA system shows up everywhere. Our HACCP corrective action post covers the CCP side.

2.6.1 Product Identification

Everything on site identified from receipt to dispatch: ingredients, packaging, part-processed product, processing aids and finished goods, and labeled as customers and regulation require, including allergen labeling on shared lines. Auditors also check start-up and changeover procedures, inspection and approval of each changeover by authorized people, and label reconciliation with any mismatch investigated. If a changeover is scheduled during the audit, be ready for it to be observed.

2.8.1 Allergen Management

A risk analysis of allergen-containing materials, processing aids and food-grade lubricants, linked to the hazard analysis; controls on allergens brought in by people and through lunchrooms, lockers and vending; identification and segregation across the site; and a list of allergens relevant where the product is made and sold. Auditors look for effective cleaning between allergen changeovers, label accuracy controls, and validation and verification that allergen cleaning works.

11.2.5 Cleaning and Sanitation

A cleaning program that sets method, frequency and responsibility for equipment, the building fabric, drains, overhead structures, amenities and utensils; validation of food contact surface cleaning, clean-in-place included; verification of detergent and sanitizer strength; an approved chemicals list with Safety Data Sheets; pre-operational inspections by qualified people; and records of cleaning, inspection and verification. Part A (A2:17) has the audit cover cleaning and pre-operational shifts as well as production, so expect sanitation to be observed, not only read about.

11.7.3 Control of Foreign Matter Contamination

Documented responsibilities for preventing foreign matter, communicated to all staff, with inspections that equipment is in good condition. Glass and similar materials are kept out of processing and food contact zones unless an exception applies, and anything needed sits on an inventory with regular inspection. Auditors also check glass breakage procedures, control of wood, loose metal, knives and snap-off blades, and inspection of wear parts such as gaskets. Note that foreign object detection (11.7.4, metal detectors and similar) is not itself a Core Clause.

Preparing your site

• Audit the 11 first. Give SQF core clauses more internal audit time, and audit them with someone who does not own the program.
• Self-score with the Edition 10 weights. A self-assessment that ignores SQF core clauses will understate your risk.
• Close systemic gaps. A major can come from a pattern of minors, so several small lapses in one Core Clause can cost far more than they look.
• Keep records running. SQFI recommends at least 90 days of records before an audit during the edition change (A2:7).

For the wider picture of what changed, see our SQF Edition 10 guide.

The SQF Edition 10 Toolkit includes a Core Clause Readiness Checklist and an Audit Readiness Self-Scoring Workbook built on the Edition 10 deductions, plus the documents behind each Core Clause, such as the Management Review Procedure, the Environmental Monitoring Program and the Food Safety Culture Assessment Plan.

SQF core clauses FAQ

Are SQF core clauses the same as mandatory elements?

No. Mandatory elements can never be reported as not applicable (A2:8). Core Clauses carry heavier deductions. Most Module 2 Core Clauses are also mandatory, but 2.4.8 is mandatory only at 2.4.8.1, and the two Module 11 Core Clauses are not on the mandatory list.

Did Edition 9 have core clauses?

No. Core Clauses are a new concept in Edition 10, so Edition 9 had no Core Clause weighting. If your internal audit and self-scoring tools were built for Edition 9, update them.

Does a critical non-conformance cost more against a Core Clause?

No. A critical costs 50 points wherever it is raised, which already takes any site below 70. At an initial audit, a critical fails the audit outright (A2:18).

Is metal detection a Core Clause?

Foreign object detection sits in 11.7.4, which is not a Core Clause. The Core Clause is 11.7.3, control of foreign matter contamination. If metal detection is a CCP in your food safety plan, though, its monitoring and verification fall under 2.4.3, which is a Core Clause.