Year-end sprint 2026: What QM and Purchasing really need to get done now
What QA and purchasing need to get done by December 2026: PFAS, BPA, EUDR, FSSC V7, IFS, BRCGS. A practical checklist with a self-assessment.
There are just over two months left until the end of the year. For QA and purchasing, the question is no longer "What's coming in 2027?", but rather:
"What should we have already taken care of? And what needs to be in place by December?"
Here is our practical checklist.
1. Food packaging: Check PFAS documentation
The new EU Packaging Regulation (EU) 2025/40 (PPWR) has been in effect since August 12, 2026. In Germany, the new Packaging Act Implementation Act (VerpackDG) came into force on the same day, replacing the previous Packaging Act.
Of particular relevance to food businesses: Since August 12, 2026, food-contact packaging must not reach or exceed certain PFAS concentrations.
The PPWR specifies:
- 25 ppb for a single targeted PFAS
- 250 ppb for the sum of targeted PFAS
- 50 ppm for PFAS, including polymeric PFAS
Packaging placed on the market before August 12, 2026, may continue to be used. The limits apply to everything placed on the market since that date.
What you need to do now:
✓ Inventory the food packaging currently in use
✓ Request up-to-date documentation from your suppliers
✓ verify that the PFAS requirements of the PPWR have been explicitly taken into account
✓ follow up on vague or blanket statements
✓ document the assessment
A simple "PFAS-free" claim from a supplier does not automatically replace the required proof.
2. BPA: Don't just look at new packaging
For Bisphenol A , the general transition period for the initial placing on the market of many food contact materials expired on July 20, 2026 .
However, that does not mean the matter is settled.
Regulation (EU) 2024/3190, as corrected by Regulation (EU) 2026/250, contains staggered transitional provisions. The most important dates:
- Reusable food contact items that were first placed on the market by July 20, 2026, may remain on the market until July 20, 2027 .
- Equipment for commercial food production may still be used until January 20, 2028 placed on the market for the first time and by January 20, 2029 .
Therefore, don't just ask: "BPA-free, yes or no?"
Better:
✓ Which material or object is affected?
✓ Single-use, reusable, or commercial production equipment?
✓ When was it first placed on the market?
✓ Which deadline applies?
✓ Is the documentation clear?
Especially with long-lasting production equipment, a thorough case-by-case assessment is worthwhile.
3. EUDR: Things are getting serious now
The EU Deforestation Regulation continues to cover the raw materials
cattle, cocoa, coffee, oil palm, soy, wood, and rubber
as well as certain products derived from them.
For large and medium-sized enterprises, application begins on December 30, 2026. For micro and small enterprises, the date is June 30, 2027.
Important: With Amending Regulation (EU) 2025/2650 of December 2025, supply chain obligations are no longer identical for all parties. Only those placing a product on the EU market for the first time are required to submit a due diligence statement. Downstream operators and traders must record and retain the reference numbers of these statements.
Therefore, simply asking "Are we buying cocoa or coffee?" is not enough.
The critical questions are:
✓ Which of our products actually fall under Annex I of the EUDR?
✓ What is our role: operator, downstream operator, or trader?
✓ Do we need to submit a due diligence statement ourselves, or just maintain reference numbers?
✓ Are our procurement and master data systems prepared for this?
Not every food manufacturer that processes an affected raw material automatically has the same obligations.
4. Legal register: "Registered" is not enough
PPWR, VerpackDG, BPA, and EUDR do not belong on a list just for the sake of it.
For every relevant change, four things should be established:
Does this affect us?
What do we need to change?
Who is responsible?
By when?
Only then does a legal register become a functional management tool.
5. Certification 2027: Conduct a gap analysis now
There is also a concrete need for action regarding standards.
FSSC 22000
Version 7 has been published since May 2026. Audits according to Version 6 are only possible until April 30, 2027 permitted. Version 7 upgrade audits will take place from May 1, 2027 to April 30, 2028 .
If you have an FSSC audit in 2027, you should therefore now:
✓ Check your audit date
✓ Compare V6 and V7 requirements
✓ Define responsibilities and implementation needs
BRCGS Food Safety
Since August 10, 2026 , the updated version 4 of Position Statement F926 for Food Safety Issue 9 has been in effect. It brings the standard into alignment with the 2024 GFSI Benchmarking Requirements.
Position statements are not just optional reading. They are mandatory and serve as an extension of the standard.
IFS Food 8
Since April 23, 2026, the IFS Food 8 Doctrine Version 5 has been available. Among other things, it includes clarifications regarding extraordinary notification requirements to the certification body, exceptional circumstances, and a more precise definition of food and product safety culture.
The same applies here: Doctrine read? Relevance assessed? Implementation documented?
6. 2026 Management Review: Start collecting data now
The most tedious part of a management review is often not the assessment itself, but the search for the necessary information.
That is why you should start gathering the following now:
✓ Complaints and customer feedback
✓ Recalls, returns, and crisis incidents
✓ Results of internal and external audits
✓ Non-conformities and corrective actions
✓ Supplier performance
✓ Food safety KPIs
✓ Verification results
✓ Training and competency development
✓ Changes in legislation, standards, and risks
This way, management can actually conduct an assessmentlater on, instead of spending time hunting for data.
The 10-minute year-end check
Can you answer these six questions off the top of your head?
1. Can we provide evidence that our food packaging meets current PFAS and BPA requirements?
2. Do we know which of our raw materials and products fall under the EUDR and what our role is in this regard?
3. Have the legal changes not only been recorded, but also evaluated and implemented?
4. Do we know which standard version our next audit will be based on?
5. Have new doctrines and position statements been evaluated?
6. Is the data for the management review already available?
Six times yes? Then you're ready for the holidays.
If you have one or more "I'd have to check" answers, there is still enough time now to close the gaps.
Publications & Technical Papers
Practical experience — passed on in specialist literature, training courses and contributions on food safety.
Director Food Safety Senior Experts, Microbiologist & Food Safety Expert
With decades of experience in audits, quality management and crisis situations, she combines scientific principles with operational practice. Her publications make complex topics such as HACCP, food safety culture and risk analysis understandable and directly applicable. For companies that not only pass certifications, but also want to sustainably improve their systems.
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