HACCP training in Greece: EU obligation and EFET national framework

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 national framework organised by EFET

The distinctive feature of the Greek system is that the national level has not left training entirely to the operator's discretion, but has organised, through EFET (Ενιαίος Φορέας Ελέγχου Τροφίμων), a national food-hygiene training programme for food-business personnel. The regulation itself requires that any national-law training requirements for people working in certain food sectors be complied with Annex II, Chapter XII, point 3 of Regulation (EC) No 852/2004: the Greek framework is the implementation of this at State level. In our view this is what most sharply sets Greece apart from models built on operator discretion alone, such as that of the Netherlands: there is a defined national reference. This does not transfer responsibility: the business must still ensure that staff receive training appropriate to their role and that procedures are actually applied Article 5(5) of Regulation (EC) No 852/2004. To avoid imprecision on the scope, content and current arrangements of the programme, the reference should be sought directly on the official EFET portal, 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, and ensure that staff receive training appropriate to their role. The regulation does not itself set minimum hours or a predefined syllabus 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), drawing on the national framework, and to keep proof that training has taken place. During official controls, EFET verifies the adequacy of staff training within the framework of Reg. (EU) 2017/625 Article 9 of Regulation (EU) 2017/625. The scope, content and current arrangements of the national programme should always be checked on the EFET portal.

The value of the certificate

There is no legally guaranteed national or EU-wide validity for a training certificate. The existence of a national programme does not turn the certificate into a title usable anywhere in the Union: a national framework is not a title with guaranteed EU-wide validity. 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 Greek system is in the Greece page; the obligation as a compliance step is in mandatory training. For a comparison with a decentralised-competence model, see the Spain page.