HACCP training in Denmark: EU obligation and national requirement

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 Danish national requirement

The distinctive feature of the Danish system is that, on top of the common EU obligation, Denmark layers a national hygiene-training requirement for staff in certain businesses handling non-prepacked food. This is not an obligation introduced by Reg. 852/2004, which in fact refers to national sector rules Annex II, Chapter XII, point 3 of Regulation (EC) No 852/2004, but a requirement administered under Danish rules. The burden stays with the business: the operator must ensure that staff in the relevant activities have the required training, just as it must apply HACCP principles with flexibility appropriate to the size of the activity Article 5(5) of Regulation (EC) No 852/2004. In our view the correct reading is this: the national requirement specifies and reinforces the underlying EU obligation, but does not turn it into a title tradeable in the abstract. The precise scope, content and current specifics should be checked with Fødevarestyrelsen, bearing in mind the last-verified date of this page.

What the business must do

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; where the national requirement applies, it must also ensure that the relevant staff have the required hygiene training. During official controls, Fødevarestyrelsen verifies the adequacy of staff training within the framework of Reg. (EU) 2017/625 Article 9 of Regulation (EU) 2017/625. The operational reference — the scope of the national requirement and practical guidance — should be sought on the official portal of Fødevarestyrelsen, bearing in mind the last-verified date of this page.

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. The overall picture of the Danish system is in the Denmark page; the obligation as a compliance step is in mandatory training. For a comparison with a decentralised-competence model, see the Spain page.