HACCP training in France: at least one trained person, 14 hours

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 French obligation: at least one trained person

It is precisely on that referral to national law that the French choice is grafted. For commercial catering, Decree No 2011-731 introduced a specific obligation: every establishment must have, on its staff, at least one person who has followed dedicated food-hygiene training. This does not mean training the entire workforce to a uniform level, but ensuring a qualified point of reference within the activity, without prejudice to the general training of all handlers required by the regulation Annex II, Chapter XII, point 1 of Regulation (EC) No 852/2004. In our view the logic is consistent with the EU scheme: responsibility remains with the food business operator, who must organise and document the establishment's hygiene competence.

The 14 hours of the order of 5 October 2011

The content and duration of the course are set by the order of 5 October 2011 (arrêté): the training lasts 14 hours and is delivered by registered training bodies. The syllabus typically covers hygiene fundamentals, microbiological hazards, the self-checking plan and documentation obligations. The 14 hours are a settled figure in the order and can be given as a reference, but they are not an EU requirement: Reg. 852/2004 sets no minimum duration Annex II, Chapter XII, point 3 of Regulation (EC) No 852/2004. For the variable details — the list of bodies, any exemptions for those holding qualifications or relevant experience, updates to the text — the reference must be sought on Légifrance and on the service-public / entreprendre portals, which describe how it applies in practice.

The value of the certificate

There is no legally guaranteed EU-wide validity for a training certificate. The French certificate documents the discharge of the national obligation under Decree No 2011-731 and is valid within that framework: it is not a title automatically usable in other Member States, where their respective national rules apply. Anyone selling courses promising a "European card", 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 French system is in the France page; the obligation as a compliance step is in mandatory training. For a comparison with a regional-competence model, see HACCP training in Italy.