LEGAL AND INSTITUTIONAL BARRIERS TO HACCP IMPLEMENTATION IN UZBEKISTAN: A COMPARATIVE ANALYSIS BASED ON CENTRAL ASIAN EXPERIENCE AND THE GERMAN APPROACH

Food safety is an essential component of public health, agricultural development, food trade, and consumer protection. The Hazard Analysis and Critical Control Point (HACCP) system is internationally recognized as a preventive approach for identifying, evaluating, and controlling biological, chemical, and physical hazards throughout the food chain. This study examines the principal legal, institutional, and technical barriers affecting HACCP implementation in Uzbekistan and compares these challenges with selected principles of food safety governance applied in Germany and reflected in international standards. A qualitative comparative approach was employed using international food safety standards, Codex Alimentarius principles, World Health Organization and Food and Agriculture Organization materials, ISO 22000 requirements, WTO sanitary and phytosanitary provisions, and publicly available information concerning food control systems. Particular attention was given to regulatory coordination, laboratory capacity, accreditation, personnel competence, documentation, traceability, and risk-based official controls. The analysis indicates that effective HACCP implementation cannot be achieved solely through the preparation of HACCP plans at individual enterprises. Its effectiveness depends on the wider national food control infrastructure, including coherent legislation, clearly defined institutional responsibilities, competent laboratories, trained personnel, traceability mechanisms, and appropriate verification procedures. A phased implementation model is proposed for Uzbekistan, combining legislative harmonization, institutional capacity development, laboratory strengthening, professional training, digital traceability, and gradual expansion of HACCP-based management practices. The study concludes that a coordinated national approach to HACCP can strengthen preventive food safety management while supporting consumer protection and improving the preparedness of food businesses for international market requirements.