HACCP training in Belgium: EU obligation, the business's responsibility

The EU obligation and the referral to Member States

The root of the obligation is single and supranational. Annex II, Chapter XII of Reg. (EC) 852/2004 requires the food business operator to ensure that food handlers are supervised, instructed or trained in food hygiene in line with their work activity Annex II, Chapter XII, point 1 of Regulation (EC) No 852/2004, and that those responsible for developing and maintaining the self-checking procedure have received adequate training in the application of HACCP principles Annex II, Chapter XII, point 2 of Regulation (EC) No 852/2004. The regulation adds an explicit referral to national law: any national-law training requirements for people working in certain food sectors must be complied with Annex II, Chapter XII, point 3 of Regulation (EC) No 852/2004. Training is also an integral part of the self-checking required by Article 5 Article 5(1) of Regulation (EC) No 852/2004: an HACCP plan handled by untrained staff is a plan with no implementation.

The Belgian specificity: training and self-checking guides

Belgium does not impose an individual health card as a condition for handling food: responsibility lies with the food business, which must ensure training appropriate to the type of activity and keep records of it. In our view the distinctive trait of the Belgian model is the integration of training and self-checking: the sector self-checking guides validated by the AFSCA — the same system described in the Belgium page — usually also set out the staff-training requirements, giving the operator a practical reference for scaling training. Adopting a validated guide is, however, neither a certificate nor an obligation: it is an optional tool that does not shift the training responsibility away from the business.

What the business must do now

The operator must organise and document the training of its staff, scaling it to the risk of the activity and the tasks performed. The regulation sets no minimum hours, predefined syllabus or mandatory refresher frequency Annex II, Chapter XII, point 3 of Regulation (EC) No 852/2004: it is for the business to identify the relevant content (personal hygiene, contamination, cold chain, allergens, self-checking procedures) and to keep proof that training has taken place. During official controls, the AFSCA verifies the adequacy of staff training within the framework of Reg. (EU) 2017/625 Article 9 of Regulation (EU) 2017/625. Since operational requirements may vary by sector, the reference must be sought in the applicable self-checking guide and with the AFSCA, as of the last-verified date shown on this page. The obligation as a compliance step is covered in mandatory training.

The value of the certificate

There is no legally guaranteed national or EU-wide validity for a training certificate. Training is not a title tradeable in the abstract but the discharge of a business obligation: its value lies in being adequate and documented for the specific activity. Anyone selling courses promising a title "recognised everywhere" or a non-existent European certification is communicating in a potentially misleading way Article 6 of Directive 2005/29/EC; on the difference between training and certification, see why no certificate exists under Reg. 852/2004. For a comparison with other national models, see HACCP training in Spain and the Italy page.