---
title: "Does Costco do its own food testing? What suppliers have to test"
description: "Costco runs its own labs and can test any product at your expense, but the testing that decides if a lot ships is yours. What V3.0 requires, by clause."
canonical: https://fsma204hub.com/blog/costco-food-testing-requirements
published: 2026-10-01
---

# Does Costco do its own food testing? What suppliers have to test

> Costco runs its own labs and can test any product at your expense, but the testing that decides if a lot ships is yours. What V3.0 requires, by clause.

**Yes, Costco does its own food testing, but not in a way that replaces yours.** Costco tests inside its own meat plants and reserves the contractual right to test any supplier's product, sample or facility, at the supplier's expense. The testing that actually decides whether your lot ships, however, sits with you: Costco's V3.0 documents require suppliers to verify sanitation, swab the environment, test water through a certified lab, run foreign material detection, and, for high-risk foods, hold every Costco lot until the finished product tests clean.

The detail decides how much testing you pay for, how long product sits in your cooler, and who eats the cost when a result comes back wrong.

Sources, so you can check every line below. All are Costco's own documents:

- [Global Food Safety Audit Expectations for Costco Suppliers, Version 3.0](https://azzule.com/wp-content/uploads/2025/08/Food-Safety-Quality-Audit-Expectations-V3.pdf), effective September 1, 2025
- [Global Food Safety Audit Expectations: Appendices, Version 1.0](https://azzule.com/wp-content/uploads/2025/08/Global-Food-Safety-Audit-Expectations_Appendices.pdf), effective September 1, 2025 (Appendix II is the testing appendix)
- [Costco Addendum V3.0 (2025)](https://azzule.com/wp-content/uploads/2025/08/Costco-Addendum-V3.0-2025.pdf), the auditor's scored form
- [Costco Wholesale Supplier Standard Terms, US, effective November 1, 2022](https://www.sec.gov/Archives/edgar/data/1852973/000121390023098345/fs42023a3ex10-23_oxus.htm), the contract terms, public only because a food supplier (Palmetto Gourmet Foods) filed its copy as an SEC exhibit

## What Costco tests itself

**Its meat plants.** V3.0 names "Costco's Tracy, CA and Morris, IL meat plants". A 2003 [Food Safety Magazine case study](https://www.food-safety.com/articles/4351-costco-wholesale-culturing-food-safety-success) described in-house microbiology labs at Costco's ground beef plant and repackaging facilities, with Costco's then food safety head saying the Tracy plant used PCR testing "all the way through" and could "analyze data on the microbiological quality of every single grind." In 2009 The New York Times [reported](https://www.nbcnews.com/health/health-news/e-coli-path-shows-ground-beef-inspection-flaws-flna1c9454862) Costco was "one of the few big producers that tests trimmings for E. coli before grinding," a practice adopted after a 1998 illness tied to its hamburger.

**Vendor and Kirkland Signature samples.** The same case study described vendor and Kirkland Signature samples sent to a headquarters lab in Washington State and checked against buyer specifications.

**Anything it chooses, on your bill.** Standard Terms section 8.3:

> "Costco (or a designated representative) may, at Supplier's expense, inspect or test any Product, sample, or Facility to determine conformity with applicable specifications and any other measure of quality, safety, design, performance, authenticity, or origin."

Costco sets the frequency "in Costco's sole discretion," can test specific runs or shipments, and can add testing "until the quality or safety issues are resolved." And section 8.3(c) closes the loop: no Costco test, approval or result "will modify or discharge Supplier's obligations."

Costco does **not** publish which products it samples, how often, or a current description of its labs; the detailed public accounts are 2003 and 2009 trade reporting. Treat its testing as a backstop that can arrive at any time, not a service.

Why it pushes testing onto suppliers came from the same food safety head in 2011, when Costco began requiring produce suppliers to test finished product for the "Big 6" E. coli strains ([The Packer, July 2011](https://downloads.regulations.gov/FDA-2011-N-0921-0001/attachment_53.pdf)): "The tests don't make the food safer, but they do tell us if the vendors' food safety programs are working."

## What you have to test, at a glance

| Test | Who it applies to | What proves it | Costco source |
|---|---|---|---|
| Sanitation verification (ATP or TPC swabs) | All operations | Validated written program, results | Addendum 3.1.9 |
| Environmental monitoring | All operations; pathogen-level detail for high-risk RTE | Written program, sampling plan, trending, corrective actions | Addendum 3.1.10, Appendix II |
| Finished goods test and hold | High-risk foods (definition below) | Sampling plan, hold and release records, results per lot | Addendum 3.1.8, Appendix II |
| Water potability | All operations | Certified third-party lab results, multiple sample sites | V3.0 Microbiological Testing |
| Foreign material detection | All manufacturing operations, with exemptions | Installed device, justification, challenge logs | Addendum 3.1.3 and 3.1.4 |
| Raw material specifications | All operations | Micro, chemical and physical acceptance criteria per material | V3.0 Supplier Approval Program |
| Label claim validation | Products claiming organic, gluten free, non-GMO and similar | Testing, certifications, or audits | Addendum 3.1.1 |

Two of these sit on Costco's critical findings list, where one miss fails the audit regardless of score: untested water, and no foreign material detection device by your anniversary audit. The [audit walkthrough](/blog/costco-food-safety-audit) covers the full list of 14.

## First question: are you "high risk"?

Test and hold is the expensive one, so start here. Appendix II defines a high-risk food as a finished product that meets **two** conditions: it falls into a category, **and** it supports pathogen growth or survival.

The categories:

1. Deemed high risk for biological hazards by a regulator in the product's market.
2. Contains a raw material that has been a known source of vegetative pathogens, and your process has no validated kill step.
3. Deemed high risk by Costco: **Kirkland Signature items**, raw ground beef, bison, veal and beef trim, ready-to-eat meats, RTE fish and seafood, fresh-cut fruits and vegetables including cantaloupe, leafy greens, frozen fruits and vegetables, **cheeses other than hard cheeses** (brie, feta, mozzarella, chevre, ricotta, queso fresco and the rest), and not-ready-to-eat foods with microwave cooking instructions that carry an internal temperature.

Two traps for craft producers. First, **Kirkland Signature is its own category.** A co-packed private label item can pull a product into test and hold that the same recipe under your own brand would not trigger. Second, the condition says growth **or survival**. A low-moisture product where Salmonella cannot grow but can persist is not automatically out.

Appendix II allows two narrow exclusions from test and hold (aseptically packed RTE products with a process authority validation, and precooked items with a kill-step cooking instruction, case by case). Neither exclusion removes the environmental monitoring requirement.

## Test and hold: every Costco lot, held until it clears

Addendum clause 3.1.8 and Appendix II set the rules:

- A **science-based sampling plan**, developed by or with a competent person, designed to detect the hazard of concern.
- Run on **all Costco production lots**, with sample size and frequency that "adequately represent the production lot."
- Samples of **finished product**, taken just before packaging or from packages. Raw material or in-process testing "does not replace" it.
- Test methods "fit for purpose and validated by a recognized 3rd party authority if available (e.g. AOAC, AFNOR, ISO)."
- Written procedures for hold and release, sampling, acceptance criteria, and corrective actions, available to Costco on request.
- Every tested lot **"must remain within the supplier's control until satisfactory test results are obtained."**

Costco's example of an appropriate plan in an RTE plant is an **N=60** plan with hourly composite grab samples, sent to an **ISO 17025 accredited laboratory** or tested on site with a recognized method. Note that this is an example, not a stated mandate. Costco does not publish a minimum sample count or a required lab accreditation for general test and hold. Ask your Costco food safety contact before you assume your current lab qualifies.

The hold rule reaches further than test and hold. Clause 3.1.8 says any finished lot that undergoes pathogen testing "voluntarily, at buyer's request, as required in product specifications, or due to regulatory requirements" must also stay in your control until results clear. If you send a sample to the lab, that lot does not ship until the result is back, even when you were not required to test it.

For a small producer the real cost is cooler space and days, not lab fees: holding every Costco lot for a lab turnaround needs a ship schedule built around it.

## Swabs: sanitation verification and environmental monitoring

Two separate Addendum clauses, often confused.

**Clause 3.1.9, sanitation verification.** All operations need a written, risk-based, validated program for food contact surfaces that does "not rely solely on visual checks." Costco names ATP monitoring or TPC swabbing as acceptable. A clipboard that says "clean: yes" scores as a missing element.

**Clause 3.1.10, environmental monitoring.** The Addendum says **all operations** must have a written environmental monitoring program, risk based and re-evaluated when deficiencies appear or at least annually. For high-risk RTE products (including frozen produce and fresh produce where water is introduced), it should define sampling frequency, number of samples, locations and method per target organism, acceptance criteria, trending, and corrective actions. Appendix II points RTE producers to FDA's Listeria guidance.

Then the line with operational teeth: where pathogen testing is done on food contact surfaces, "all product lots processed over the swabbed surface(s) since the last validated sanitation cycle shall remain within the supplier's control until satisfactory test results are obtained." A Listeria swab on a slicer holds every lot that ran across it since the last validated clean. Knowing which lots those were is a records question, not a lab question.

## Water: an automatic failure if untested

V3.0 requires water from a potable source, tested by a **certified third-party laboratory**: municipal water **annually**, private wells **quarterly**, samples drawn from various sites in the facility, records kept, and processing or sanitation water tested for **generic E. coli**. Irrigation water must meet the FDA Produce Safety Rule.

This is the cheapest test on the list and one of the most expensive to skip. "Water potability is not tested by a certified laboratory and records are not maintained" is a critical finding. A municipal supply does not exempt you: the city's report is not your sample from your taps.

## Foreign material: the x-ray question

**Costco no longer requires x-ray.** The V2.0 expectations, effective April 1, 2023, required most manufacturers to install "a properly installed and calibrated X-ray detection device for finished product." V3.0's change log records it plainly: "Removed: mandatory x-ray requirement." Equipment vendor pages still ranking for this question describe the 2023 rule.

What V3.0 requires instead (Addendum 3.1.3 and 3.1.4):

- A foreign material detection system (metal detection, x-ray, sieves, optical sorter and similar), chosen as the most effective option for your product, **justified with documented scientific and technical evidence**.
- A rejection mechanism that physically segregates rejects under restricted access.
- Documented challenge tests at the start and finish of each production day or shift, at intervals of **2 hours or less** during the run, at batch changes, at machine setting changes, and after repair downtime.

Exemptions: shell eggs, whole raw agricultural commodities, whole roasted coffee beans, whole muscle meats, certain whole seafood, and packaging products, plus operations using an appropriately sized screen, filter or sieve placed just before packaging (with integrity checks). Not having a device installed by your anniversary audit, without an exemption or an agreement with Costco food safety, is a critical finding.

## Category rules that are stricter still

In these categories, the general rules are the floor:

- **Ready-to-eat produce.** Tested for TPC, generic E. coli, Salmonella, STECs and Listeria monocytogenes. Out-of-spec product "cannot be shipped to Costco without a variance," granted only for TPC, and every lot's results are uploaded to Azzule at shipment.
- **Frozen fruits and vegetables.** Frozen vegetables not enrobed in sauce count as ready to eat, whatever the cooking instructions say. Minimum Salmonella and STEC testing (berries add Hepatitis A), uploaded by PO before delivery: "Attempted PO deliveries without test results will be rejected."
- **Ground beef, bison, veal and beef trim.** N=60 per 2,000 pounds for E. coli O157:H7 by an AOAC-approved PCR method, pulls every 15 minutes combined into hourly composites, plus indicator limits (TPC 100,000 cfu/g, coliform 500 cfu/g, E. coli 100 cfu/g). Nothing leaves the plant without a negative.

## When a test fails

**Before the product ships,** the hold contains it by design. Appendix II requires the root cause analysis, corrective actions and retesting results for any positive environmental result to be available to Costco Food Safety on request. Costco's ground beef rule shows how wide the hold goes: a positive puts "all product from that production date" on hold, disposition by the regulator, and contaminated product goes to lethality, rendering or landfill.

**After the product ships,** it is a recall. V3.0 requires the supplier to contact Costco's buying team, Costco's recall teams, and any affected international food safety teams **within 24 hours** of an actual recall. Costco may also order an immediate food safety audit outside your normal cycle in response to a recall, and "vendors are responsible for the cost of the re-audit related to audit failures and recall/regulatory issues."

**Who pays.** Section 16 of the Standard Terms is unambiguous. Whether the recall is "initiated by Costco, Supplier, or a government or consumer protection agency," the supplier "shall take appropriate actions and pay all associated costs and expenses," and reimburse Costco for:

- recalling, publishing and mailing notices, and investigating
- storing, shipping, destroying or recycling the product, **and any products it was processed, packaged, combined or commingled with**
- refunds to members, and any compensation Costco gave members not to return the product
- Costco's Net Landed Cost for the product

Section 11 lets Costco **offset** amounts you owe against amounts it owes you and hold back a reserve "in an amount determined in Costco's sole discretion." Section 12 makes you defend and indemnify Costco against third-party claims, including injury claims. Section 17 excludes consequential damages but preserves Costco's recovery of its margin (Net Landed Cost to selling price) when you are in breach.

What is not public: the version you will sign. Costco updates the Standard Terms through its Supplier Portal with at least 30 days' notice, and the 2022 copy quoted here has its insurance minimums and one rejection fee percentage redacted. Read the recall and insurance sections of your own Supplier Agreement before the first PO, and price product liability and recall coverage against them.

## Where FSMA 204 fits

FSMA 204 does not require you to test anything. It is a recordkeeping rule ([the KDE checklist](/blog/fsma-204-kde-checklist) lists every element) with a federal compliance date of July 20, 2028, while retailers enforce their own dates now ([the deadline table](/blog/retailer-fsma-204-deadlines)). Still, much of Costco's Category 3 (soft cheeses, leafy greens, fresh-cut produce, melons) also sits on FDA's Food Traceability List.

Testing and traceability meet at one decision: **what you call a lot.** Costco wants sampling that "adequately represent[s] the production lot," and every hold rule above is scoped to lots. A positive on a lot defined as one hour of one line costs an hour of product. A positive on a lot defined as "the week" costs the week, and if any of it already shipped, that is a section 16 recall, including whatever it was commingled with. The same records answer the swab question: which lots ran across that surface since the last validated clean.

That is the case for [lot codes that are actually unique](/blog/what-is-a-traceability-lot-code), receiving records tied to the batches that consumed them, and a drill you have actually timed ([the 24-hour traceback walkthrough](/blog/mock-24-hour-traceback) is a good template; Costco's own clock, covered in [the Addendum teardown](/blog/costco-addendum-traceability-requirements), is 2 hours). On the inbound side, the micro, chemical and physical specs Costco requires for every raw material are easier to defend with a supplier file that holds more than a [letter of guarantee](/blog/supplier-letter-of-guarantee).

## What Costco does not publish

To save you a search:

- How often Costco itself samples or tests a given supplier's product, or which products it targets.
- A current description of its in-house lab program (the detailed public accounts date from 2003 and 2009).
- A required lab accreditation or minimum sample size for general test and hold (ISO 17025 and N=60 appear only as an example).
- The type of certification required for the water lab beyond "certified third-party laboratory."
- The current Standard Terms text, insurance minimums, or any recall cost cap. The 2022 terms contain no cap.

## The short version

Costco tests, Costco can test you, and you pay either way. The testing that keeps a lot out of a recall is yours. The [supplier traceability map](/blog/costco-supplier-traceability-requirements) shows where it sits in the wider Costco program.

The part software can do is the lot math. [FSMA204Hub](/) links supplier lots at receiving to the batches that consumed them and forward to what shipped, so a positive result turns into a short list of affected lots instead of a guess. If a Costco packet is on your desk, [the free readiness score](/score) takes two minutes, and [the 14-day trial](/sign-up) needs no credit card.

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*Written by [Anas Marwan](/authors/anas-n), Co-founder of Darza Technologies. Sources: Costco Global Food Safety Audit Expectations V3.0, Appendices V1.0 and Costco Addendum V3.0 (2025), as published through Azzule Systems; Costco Wholesale Supplier Standard Terms (US, effective November 1, 2022) as filed with the SEC; Food Safety Magazine (2003); The New York Times (2009); The Packer (2011). Last reviewed 2026-10-01.*

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Source: https://fsma204hub.com/blog/costco-food-testing-requirements (https://fsma204hub.com)