Changes to Costco Food Safety Audit Expectations

Costco has announced changes to their food safety audit expectations for all sites, which are published in their Costco Food Safety GMP Audit V3.0 and their Global Costco Food Safety Audit Expectations V3.0 published September 1, 2025. . You might be wondering how these changes impact your business. Several of the key changes to Costco Food Safety Audit expectations are summarized below.

At a minimum Costco continues to expect food safety audits to be conducted annually. As of September 2025, the following Unannounced vs. Announced Costco audit expectations will apply:

Costco Food Safety GMP Audits will remain unannounced.
For GDP or Packaging Audits, Costco will defer to the standard owner’s requirements to determine if audits will be announced vs. unannounced.
- Examples of private standard owners that are approved to perform Costco audits are: ● Acerta Spain ● AIB International ● Asure Quality ● AUS-Meat / AUS-Qual ● BNQ ● BSI Group ● Bureau Veritas ● Control Union ● DNV-GL ● Eagle Food Registrations ● Eurofins ● FoodChain ID ● Food Safety Net Services ● Global STD ● Intertek / SAI Global ● LRQA ● LSQA ● Mérieux ● MSVS (Produce) ● NSF International ● PMC ● Primus Auditing Operations (PAO) ● Safe Food Certifications ● SCS Global Services ● SGS ● TSLC (Produce) ● TUV USA / TUV Nord ● UL Solutions ● Validus ● WQS-QIMA / QIMA
The unannounced vs. announced audit cycle for GFSI-recognized scheme audits including SQF, BRCGS, PrimusGFS, FSSC 22000 etc… will follow the Certification Program Owner (CPO)’s requirements.

Key Updates With Costco Food Safety GMP Audit V3.0

Costco continues to expect at least 60 days of production records or an automatic failure will be given. Costco now has a flag for “Automatic Failure”.
The name of the Costco audit is changing from “Costco Food Safety Audit” to Costco Food Safety GMP Audit.
For finished food products that are shipped to an intermediary facility prior to delivery to a Costco depot or warehouse, there must be an annual mock recall documented, which includes: evidence of communication with the intermediary facility, including verification of contact information and quantity reconciliation to the specific lot code.
All manufacturing operations must have a foreign material detection system (metal detection, x-ray, sieves, optical sorter etc.) installed, selecting the most effective solutions available for their products and processes.
Costco added additional expectations surrounding use of hair-nets, facial hair covering, and gloves.
Costco provided clarification regarding a required Finished Goods Test and Hold Program for Suppliers of high risk ready-to-eat (RTE) food items, and some high risk not-ready-to-eat (NRTE) food items.
Each facility must have a written and validated sanitation program for food contact surfaces. Kellerman Consulting includes this as part of every food safety certification program. Costco added additional language regarding what is expected for validation of sanitation.
Items imported into the U.S. must have a Foreign Supplier Verification Program (FSVP) letter from Costco, and Costco added language to state that there are exemptions for some items if they are exempt in 21 CFR 1.501 Kellerman Consulting can write and help you implement your FSVP program.

Please note: Costco may initiate an immediate Costco audit in response to a product recall, serious incident, issue of an FDA warning letter, or Costco concern. The list above does not cover all of the recent changes. For the full list of changes, please contact your certifying body to request the Costco audit expectations.

If you’re overwhelmed or require assistance to meet these new Costco Food Safety Audit expectations, contact us for a free 30 minute consultation at: (800) 535-1376 or INFO@KELLERMANCONSULTING.COM