Bars and cafés: hygiene obligations under Reg. (EC) 852/2004

Updated 2026-07-12 · Reviewed by: Redazione ce85204 — revisione editoriale assistita da AI (2026-07-12)

A bar is a food business operator: it must register under Art. 6 of Reg. (EC) 852/2004 and apply procedures based on HACCP principles under Art. 5. For simple food service a flexible application is allowed, not an exemption: hazard analysis is still required.

Bars, cafés and snack counters mostly carry out simple food service: coffee, drinks, ready-to-eat products, snacks and light preparation. Whoever runs the business is a food business operator (FBO) and takes on the obligations of Regulation (EC) No 852/2004. The distinctive feature of the sector is the HACCP regime, which may be applied in a simplified form but is never an exemption.

Simplified HACCP: what it really means

In simple food service it is often not possible to identify genuine critical control points: coffee, packaged drinks and counter products do not go through a critical heat process. Recital 15 of the Regulation and Commission Notice 2022/C 355/01 recognise that, in such cases, good hygiene practices may replace the monitoring of CCPs and documentation may be reduced Article 5(2) of Regulation (EC) No 852/2004.

Here is the point consultants most often get wrong: the simplification concerns the how, not the whether. The Article 5 obligation remains full; what is reduced is the form of the procedures and of the documentation. In particular:

• hazard analysis must still be carried out, and the choice not to identify CCPs must be justified and remains open to challenge during official controls Article 5(4) of Regulation (EC) No 852/2004;
• the prerequisite programmes (PRPs) — cleaning, cold chain, personal hygiene — become the main content of the system;
• as soon as the bar prepares food involving cooking, chilling or holding (hot counter, kitchen), the picture moves closer to that of restaurants, with identifiable CCPs.

Which 852 obligations apply

If the bar makes sandwiches or dishes, Chapter II on preparation rooms is added. The cold chain of perishable products and allergen management remain specific obligations. In Italy registration is made through the health SCIA notification (registration and SCIA); training follows regional rules (HACCP training in Italy).