CODEX 2026

Everything Codex Changed in July 2026, and What South African Manufacturers Must Do

By Mthokozisi Nkosi, Food Safety Specialist & Lead Auditor, ASC Food Safety · 15 min read

The July 2026 Codex session was CAC49, not CAC48, and it added a precautionary allergen labelling annex to CXS 1-1985 with reference doses of 2.0 mg of protein for peanut, egg, milk and sesame. CAC48, in November 2025, set lead at 2.5 mg per kilogram in dried bark spices. CXC 1-1969 did not change. ASC risk assessment packs are R690 each.

Was the July 2026 Codex session CAC48 or CAC49?

It was CAC49, the 49th Session of the Codex Alimentarius Commission, held from 6 to 10 July 2026 at the Centre International de Conferences Geneve in Geneva, with about 600 delegates from 119 members. CAC48 was the 48th Session, held from 10 to 14 November 2025 at FAO headquarters in Rome. The two sessions adopted different things, so the number is not trivia.

The confusion has a cause. The Commission moved its 2025 meeting to November, which put two sessions inside eight months, and a great deal of secondary commentary wrote up the Geneva meeting under the older number. If your supplier sends you a specification update citing CAC48 for the allergen annex, the citation is wrong even where the content is right, and a customer auditor who checks it will treat the whole document as unverified.

The mechanics are worth stating once. The Commission meets annually and adopts, in one batch, everything its subsidiary committees have forwarded. Nothing is negotiated on the floor in Geneva or Rome. The work happens in the Committee on Food Labelling, the Committee on Contaminants in Foods, the Committee on Food Hygiene, the Committee on Pesticide Residues and the rest, sometimes over a decade, and the Commission session is where it becomes a Codex text. So when you read that Codex changed something in July 2026, the change was argued out years earlier and your export customers have been watching it coming.

The current strategic period is the Codex Strategic Plan 2026 to 2031, adopted at CAC47 in 2024, with its monitoring framework adopted at CAC48 in November 2025 and the plan published online in all six United Nations languages on 8 July 2026. That is the frame the committees are now working inside, which tells you where the next round of changes will come from.

Every Codex change from CAC48 and CAC49, with the action it forces

The table below lists every change ASC verified from the two sessions, the text it lands in, and what a South African manufacturer must do about it. Where a change is marked as adopted with the consolidated text not yet republished, or as reported from the session outcome, treat the figure as directional until you have read it in the Codex text yourself.

Twenty-two rows, and only six of them will apply to any one site. That is the useful thing about a change table: it lets you close the file on everything that does not touch your scope, and gives you a written record that you checked.

Allergens: a new annex to CXS 1-1985, with reference doses for 21 allergenic foods and for gluten

CAC49 added a new annex to CXS 1-1985, the General Standard for the Labelling of Prepackaged Foods, titled Guidelines on the use of precautionary allergen labelling. The published standard’s cover now reads adopted 1985, CXS 1-1985, amended 2026. Its history note records that following decisions at the 49th Session in 2026, sections 4.2.2, 4.3.4, 4.7.1(vii) and 8.1.3.1 were revised and the annex was added.

The logic of the annex is the part that changes how you work. Precautionary allergen labelling is permitted only after allergen management measures are in place and a risk assessment shows the residual risk cannot be adequately controlled. Where it is used, the statement must begin with “may contain” or an equivalent phrase. So the annex does two things at once: it disciplines the defensive “may contain” that goes on the label because nobody wanted to do the work, and it gives you a numeric basis for deciding.

Those numbers are the reference doses in Table A1, expressed in milligrams of total protein from the allergenic source, for IgE mediated food allergy. One milligram covers almond, Brazil nut, cashew, pistachio, macadamia, pine nut, walnut, pecan, celery and mustard. Two milligrams covers peanut, egg, milk and sesame. Hazelnut is 3.0 mg, wheat and fish are 5.0 mg, buckwheat, lupin and soy are 10.0 mg, and crustacea is 200.0 mg. Table A2 deals with coeliac disease and gives 4.0 mg of total gluten for cereals containing gluten, meaning wheat, rye and barley.

CXC 80-2020, the Code of Practice on Food Allergen Management for Food Business Operators, was amended at CAC49 and the published text carries amended 2026. Its introduction, its scope at section 2.1 and its definitions at section 2.3 were amended to align with the revisions to CXS 1-1985 adopted at CAC47 in 2024, on the list of foods and ingredients known to trigger food allergy or coeliac disease. The alignment target is that 2024 revision, not the 2026 annex.

A “may contain” statement is now a conclusion you have to show your working for, not a sentence you add because you are not sure.

None of this is South African law. Regulation 43 of R146 of 2010 remains the allergen declaration rule here and its list is unchanged: egg, cow’s milk, crustaceans and molluscs, fish, peanuts, soybeans, tree nuts, and cereals containing gluten. Sulphur dioxide is not on that list, although regulation 38 requires it to be declared at 10 mg per kilogram or more, and at any level in certain cases such as transfer from packaging materials and treated fresh produce. R146 has no precautionary allergen labelling rule at all, which is precisely why the Codex annex matters here: it is the reference an importing authority, a retailer’s technical team or an expert will reach for where our own regulations are silent. The full mechanics of the annex and the doses are set out in our companion guide on the Codex may contain annex and the allergen reference doses, and our existing allergen labelling guide for South Africa covers regulation 43 itself.

Did CXC 1-1969 change in 2026?

No. CXC 1-1969, the General Principles of Food Hygiene, did not change at CAC49 or CAC48. The published text still reads adopted 1969, amended 1999, revised 1997, 2003, 2020 and 2022, with editorial corrections in 2011. The 2022 revision, with its HACCP annex, seven principles and twelve steps, remains the current text. There is no 2026 edition.

This needs saying because the false claim circulates, and it circulates in expensive places. A trainer sells a course on the “2026 General Principles”. A consultant issues a gap analysis against a document that does not exist. A supplier sends you a corrective action plan citing a 2026 revision, and your own document register quietly acquires a wrong version reference that an auditor will find.

A revision is in progress at the Codex Committee on Food Hygiene, and it will eventually reach a Commission session. Until it is adopted, the correct citation in your HACCP plan, your prerequisite programme documents and your training material is CXC 1-1969, General Principles of Food Hygiene, revised 2022, 2023 edition. Never write CAC/RCP, which is the old numbering and marks a document as out of date on sight.

Contaminants: lead limits added to CXS 193-1995 for dried bark spices and dried culinary herbs

CAC48, in November 2025, amended CXS 193-1995, the General Standard for Contaminants and Toxins in Food and Feed, adding maximum levels for lead of 2.5 mg per kilogram in dried bark spices such as cinnamon and 2.0 mg per kilogram in dried culinary herbs. The same amendment removed outdated radionuclide guidance. The published cover reads adopted in 1995, last amended in 2025.

For a South African manufacturer this is a supplier question before it is a product question. Dried spices and herbs are among the most traded, most blended and least traceable inputs in the food chain, and lead arrives in them from soil, from processing equipment and, in documented international cases, from deliberate adulteration to add weight and colour. If your spice specification says “complies with applicable legislation” and nothing else, it does not say anything.

• Add the numeric lead limit to the raw material specification for every dried bark spice and dried culinary herb you buy.
• Ask for a certificate of analysis that reports lead, with the method and the limit of quantification, not a generic conformity statement.
• Decide a verification frequency for your own testing and write the reasoning down, because the auditor will ask why that frequency.
• Record the change in your supplier approval file so there is a dated trail from the Codex amendment to the specification reissue.
• Treat the four new spice standards, CXS 366-2026 to CXS 369-2026, as the same review, since they cover curry leaves, vanilla, large cardamom and coriander.

Two ASC packs carry this work. The Chemical Contamination Risk Assessment at R690 is where the heavy metal reasoning belongs, and the Supplier and Purchased Material Approval Risk Assessment at R690 is where the certificate of analysis regime and the approval decision belong. The detail on the limits themselves, including how they interact with existing national requirements, is in our article on the new Codex lead limits for spices and herbs in South Africa.

Listeria: CXG 61-2007 revised and the ready to eat definition widened

CXG 61-2007, the Guidelines on the Application of General Principles of Food Hygiene to the Control of Listeria monocytogenes in Foods, was fully revised at CAC49 and the published text carries revised 2026. The revision introduces a new ready to eat definition built on what consumption is reasonably foreseeable.

Verbatim, it is “any food (raw or processed) for which it is normally eaten without further validated treatment sufficient to achieve food safety, or for which it is reasonably foreseeable, based on evidence of consumer habits or practices, that it will be eaten without such treatment.”

Three foods are named in the introduction to the revised guideline: diced cantaloupe, frozen vegetables and cold smoked fish. They are named as the three foods for which JEMRA has published open-source quantitative risk assessment models, not as products Codex says the definition reaches. The guideline separately observes that some foods linked to listeriosis outbreaks, certain frozen vegetables among them, were intended by the food business operator to be cooked by the consumer. Codex publishes no list of the foods the definition reaches. You apply it to your own range and write the answer down.

Read that definition slowly, because it moves the boundary of your environmental monitoring programme. The old habit was to ask whether a product is intended to be eaten without further cooking. The new question is whether it is reasonably foreseeable that a consumer will eat it that way. Frozen vegetables are the clearest example. The pack says cook before eating. People eat them from the bag, blend them into smoothies and add them to salads part thawed, and that has been foreseeable for years.

South African readers do not need reminding what this pathogen does. If a product has moved into the ready to eat category on the new definition, three documents change together: the Microbiological Contamination Risk Assessment at R690, the Environmental Monitoring Risk Assessment at R690 and the sampling plan that sits under it. The sampling plan is where sites lose marks, because sample sites are chosen once and then never tied back to a written rationale. Our companion article on the wider ready to eat definition and environmental monitoring after the 2026 Listeria revision works through zone one to zone four sampling and the corrective action ladder.

Additives: INS 475 reduced in 19 of 56 provisions and revoked in six

CAC49 reduced use levels for 19 of the 56 provisions for polyglycerol esters of fatty acids, INS 475, in CXS 192-1995, the General Standard for Food Additives, and revoked six provisions outright, after JECFA advised that the acceptable daily intake could be exceeded.

The two are not the same instruction. A reduced level is a reformulation, the additive stays and the dose comes down. A revoked provision means INS 475 is no longer permitted in that food at all. The standard’s cover now reads revised 2026. CAC48 had already revised more than 500 additive provisions, most of them colours.

Among the colour decisions, two are worth naming because they catch specific South African product lines. Bixin-based annatto extracts were revoked in fermented milks, and norbixin-based annatto extracts were adopted in pasteurized, canned or bottled fruit. Annatto is not one additive. If your recipe card says “annatto” and your supplier ships whichever form is cheapest that month, you cannot answer the question the GSFA now asks. CXG 36-1989, Class Names and the International Numbering System for Food Additives, was also revised in 2026, which is a labelling matter as much as a formulation one.

INS 475 is an emulsifier that shows up in bakery, confectionery, fat spreads and beverage emulsions. A reduction across 19 provisions, with six more revoked outright, is the kind of change that does not trigger any alarm in a South African plant, because our own additive permissions are set nationally, and then becomes an export rejection eighteen months later. The practical step is a formulation audit against the revised provisions, market by market, starting with the six that were revoked. If your team needs the labelling side of this properly grounded, the Advanced Food and Beverage Labelling course at R2,950 and the Labelling Claims and Regulatory Framework course at R1,750 are both self paced online with lifetime access and a QR verifiable certificate, and ASC charges no VAT on training, so the price shown is the price paid.

Residues: five pesticides lost every Codex MRL

CAC48, in November 2025, adopted 340 maximum residue limits for different combinations of pesticide and commodity, a figure recorded in the adopted report REP25/CAC. The same session revoked all maximum residue limits for fenthion, parathion-methyl, dinocap, amitraz and bitertanol, and revoked methamidophos limits for cottonseed, fodder beet, potato and sugar.

The revocation list is confirmed at committee level and in the body of the adopted report, so check it against the Codex text before you build a specification on it.

A revoked MRL is not a relaxation. It is the removal of the international benchmark that an importing country was using, and the practical effect for an exporter is usually the opposite of permissive: without a Codex limit, the importing authority falls back on its own national limit, which is often a default at the limit of quantification. For a South African fruit, nut or grain exporter, that is a rejected consignment at the port rather than a paperwork query.

On the veterinary side, CAC49 adopted the first camelid MRLs in CXM 2, covering tetracyclines in camelid kidney, liver, milk and muscle and ivermectin in camelid milk, plus action levels for lasalocid and nicarbazin in chicken eggs. The published CXM 2 still reads CXM 2-2024 and carries none of it, so confirm each of these against the Codex text before you write it into a specification. The egg action levels are the ones with local relevance. The current antimicrobial resistance texts remain CXG 94-2021 on integrated monitoring and surveillance of foodborne antimicrobial resistance and CXG 77-2011 on risk analysis of foodborne antimicrobial resistance, adopted in 2011 and revised in 2021. Our article on the five revoked pesticide MRLs and what exporters must check sets out the commodity by commodity position.

Mycotoxins: CXC 55-2004 revised for peanuts, the first revision in over twenty years

The code of practice for the prevention and reduction of aflatoxin contamination in peanuts was revised at CAC48, its first revision in more than twenty years. It adds a table of peanut reproductive growth stages to guide harvest timing, extends its scope to feed made from peanut by-products, and adds a new section on the part roasting plays in reducing aflatoxin. The maximum levels themselves did not move. Those stay in CXS 193-1995. South African groundnut handlers and buyers should read the revised peanut aflatoxin code of practice in full.

Water: two new annexes to CXG 100-2023, one of them on reuse

CAC49 adopted two new annexes to the Codex guidelines on the safe use and reuse of water, one on fish and fishery products and one on fit for purpose assessment, safety management and technologies for recovering reusable water, with consequential amendments to the existing sections. FAO had not republished the consolidated CXG 100-2023 when ASC checked on 10 September 2026, so work from the CAC49 adopted report until it appears, and check the published guideline before you write a specification against the annex wording. In a water scarce country this is the text that makes a reuse decision defensible, and it is covered in the 2026 Codex water reuse annexes.

The new Codex texts adopted in 2025 and 2026

CAC49 adopted CXG 108-2026, Guidelines on the Application of Food Labelling Provisions in Emergencies, and CXS 370-2026, the Standard for Baker’s Yeast, which is the first commodity standard ever developed by the Codex Committee on Food Additives. It also adopted four spice standards, CXS 366-2026 to CXS 369-2026. CAC48 adopted CXS 363-2025 for fresh dates and CXG 106-2025 on pesticide reference materials.

CXG 108-2026 deserves a paragraph on its own, because it is the text most likely to be misread. It lets a competent authority temporarily permit departures from specific labelling requirements during a supply disruption or emergency, provided the flexibility is risk based, proportionate, and does not mislead the purchaser or endanger vulnerable groups. It is permission for a regulator to grant relief, not permission for a manufacturer to take it. In South Africa the competent authority is the National Department of Health under the Foodstuffs, Cosmetics and Disinfectants Act 54 of 1972, and no such relief has been granted. Put the guideline in your emergency preparedness file as the reference you would cite in an application, and nowhere else.

The rest are specification documents. CXS 370-2026 belongs in your yeast supplier questionnaire. The four spice standards belong with the new lead limits in the same spice review. CXS 363-2025, the first international standard for fresh dates, and CXS 362R-2025, the regional standard for Castilla Lulo, matter to importers. CXG 106-2025 is one for your contract laboratory, because it lets a laboratory keep using a pesticide reference material past its expiry date where purity is demonstrated to remain acceptable, which changes how you read an expired standard on a test report. CXS 234-1999, Recommended Methods of Analysis and Sampling, was restructured and republished and its cover reads amended 2026.

Every one of these is a free download from FAO. Nobody should be selling you a copy of a Codex text. ASC keeps a ASC Codex and guidelines register with the full 2025 and 2026 change log, alongside a ASC South African legislation register and a standards and certification scheme register. All three are free to use.

Does any of this bind you legally?

No. Codex is not South African law. The law is R146 of 2010 for labelling, R638 of 2018 for general hygiene requirements and certificates of acceptability, the Foodstuffs, Cosmetics and Disinfectants Act 54 of 1972 above both, and the category regulations such as R.733 of 2012 for sweeteners and R.1769 of 1985 for soft drinks. Codex reaches you through customers, schemes and importing authorities.

That is not the same as saying it does not bind you. Four routes bring a Codex text into a South African factory with real force. Your export customer writes it into the specification. Your certification scheme references it, as FSSC 22000 and BRCGS reference Codex hygiene principles. An importing authority applies it under the WTO Agreement on the Application of Sanitary and Phytosanitary Measures, where Codex is the named reference for food safety. And in a dispute, where our own regulations are silent, Codex is the standard an expert will testify against, which matters a great deal under section 61 of the Consumer Protection Act 68 of 2008, which imposes liability on producers, importers, distributors and retailers for harm caused by unsafe goods, product failure, defects or hazards, or by inadequate instructions or warnings, irrespective of negligence.

Precautionary allergen labelling is the clean illustration. R146 has no rule about it at all. If a consumer is harmed by a product that carried no “may contain” statement, the question in the room becomes what a reasonable manufacturer should have done, and the annex to CXS 1-1985 is the document that answers it. The full legal analysis sits in our article on whether Codex Alimentarius is law in South Africa, and the wider statutory picture is in the South African food legislation guide.

A 90 day plan for a South African QA manager

Work in the order the risk sits, not the order the table is printed. Specifications first, because a wrong number in a specification travels to every supplier and every batch. Then allergens, because that is where the liability is. Then environmental monitoring, because the ready to eat definition moved. Then document control, because that is where the wrong citations hide.

1. Days 1 to 10: build the scope listGo down the change table and mark each row applies, does not apply or need to check. Sign and date it. That page alone answers the auditor’s question about how you monitor legislative and Codex change.
2. Days 10 to 30: specifications and certificates of analysisPull every raw material specification quoting a pesticide MRL, a heavy metal limit or an additive use level. Fix the lead limits for spices and herbs, and remove the revoked MRL references. Reissue with a version number.
3. Days 20 to 45: the allergen decisionFor each product, record whether a precautionary statement is used, on what cross contact evidence, and against which reference dose. Where you carry a “may contain” you cannot justify, take it off. Where you carry none and cannot show why, that is the bigger finding.
4. Days 30 to 60: ready to eat determinationRe-run it for every product against reasonably foreseeable consumption. Where a product moves in, update the microbiological and environmental monitoring risk assessments and the sampling plan together, with the rationale written on the document.
5. Days 45 to 70: water and utilitiesIf you reuse water anywhere, or you are on a restriction regime, start the fit for purpose argument now, in the Utilities, Water, Air, Steam and Lighting Risk Assessment at R690. The CXG 100-2023 annexes were adopted at CAC49 and the consolidated text had not been republished when ASC checked on 10 September 2026, so build the reasoning and slot the reference in later.
6. Days 60 to 80: document control sweepSearch for CAC/RCP, for a 2026 edition of CXC 1-1969, and for any citation of the July 2026 session as CAC48. Correct all three and record the correction.
7. Days 80 to 90: train and close outBrief the QA team, the technologists and the buyers on what changed and what it means for their own documents. Close the scope list with evidence against every row marked applies.

If that reads like six weeks of work you do not have, it is, and it is exactly the kind of project ASC scopes and quotes as one figure rather than billing by the hour. Hourly consulting is available from R480 where you want a second opinion on a single decision rather than a project. Our complete guide to food hygiene audits covers how the evidence you build here is then tested at the audit table.

Schemes: the versions moved in the same window

Codex was not the only thing moving in 2026. ISO 14001:2026, edition 4, was published on 15 April 2026 and ISO 14001:2015 is withdrawn. A sixth edition of ISO 9001 is scheduled for publication on 16 September 2026 and had not been published when ASC checked on 10 September 2026. A publication date is not a compliance date, and existing certificates stay valid.

The accreditation picture is the part causing needless anxiety. The International Accreditation Forum ceased operations on 1 January 2026 and its work moved to Global Accreditation Cooperation, known as Global ACI. As at 10 September 2026 no transition document had been published for either ISO 9001 or ISO 14001, so no global transition deadline exists yet. Anyone selling you a transition deadline is selling you a date nobody has set. Ask your certification body in writing, and plan rather than panic.

The two BRCGS position statement documents are hosted on this site: Food Safety Issue 9 position statements version 4 and Storage and Distribution Issue 4 position statements version 8.1. Two companion articles carry this further: what certified sites must do about ISO 9001 and ISO 14001 in 2026 and which scheme version applies to your audit in 2026. If your site is heading into the Version 7 upgrade, our FSSC 22000 Version 7 guide for South Africa covers the change in full, and the Transition to FSSC 22000 Version 7 course at R1,450 is the short route for a team that already knows Version 6.

Frequently asked questions

Published by ASC Food Safety, South African food safety and quality consultants. This article is general guidance and not a substitute for certification-specific advice.