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Check your food hygiene obligations by type of activity

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

Obligations under Reg. (EC) 852/2004 vary by activity type. Primary production: Annex I, exempt from HACCP (Art. 5(3)). From later stages: registration (Art. 6), HACCP procedures (Art. 5), Annex II requirements and training. Approval (Art. 6(3)) applies only to certain establishments.

Food hygiene obligations are not the same for everyone: they depend on the stage of the chain and the type of activity. This reasoned checklist sets out, for six typical categories, the duties that apply under Regulation (EC) No 852/2004 and related law, with the legal basis and a link to the detailed page. It does not replace a case-by-case assessment, but it helps you get your bearings. The interactive tool below generates the checklist for your type of activity and lets you print it or save it as a PDF; the commentary that follows explains its legal basis.

Interactive obligation checker

1. What type of activity do you run?

At a glance

Commentary

Identify your type of activity

The first step is to place the activity in the chain. Reg. 852/2004 distinguishes primary production and associated operations — governed by Annex I Annex I, Part A, point 2 of Regulation (EC) No 852/2004 — from all later stages, to which Annex II and the HACCP duty apply Article 5(3) of Regulation (EC) No 852/2004. A business may fall into more than one category: a dairy with direct sales is both processing and retail. In that case the obligations add up.

Check registration or approval

Every operator notifies each establishment to the competent authority for registration Article 6(2) of Regulation (EC) No 852/2004. Approval — a measure subject to an on-site visit — is instead required only where Reg. (EC) No 853/2004 or national law demands it Article 6(3) of Regulation (EC) No 852/2004.

Put HACCP-based procedures in place

From stages after primary production it is mandatory to establish, implement and maintain permanent procedures based on the HACCP principles Article 5(1) of Regulation (EC) No 852/2004, with the flexibility allowed to simple businesses. The procedures rest on hygiene prerequisites and are usually set out in the food safety management manual.

Apply the structural and hygiene requirements of Annex II

The general requirements of Annex II cover premises, equipment, water supply, waste, personal hygiene and the cold chain, with specific chapters for particular situations. Which chapters apply depends on the activity, as detailed in the per-category checklist below.

Ensure staff training

Food handlers must be trained Annex II, Chapter XII, point 1 of Regulation (EC) No 852/2004 and those responsible for HACCP adequately instructed Annex II, Chapter XII, point 2 of Regulation (EC) No 852/2004. The arrangements are national or regional.

Checklist by type of activity

Primary production (growing, rearing, hunting, fishing, harvesting). Requirements of Annex I, Part A Annex I, Part A, point 2 of Regulation (EC) No 852/2004; registration of the establishment Article 6(2) of Regulation (EC) No 852/2004; traceability Article 18 of Regulation (EC) No 178/2002; records on treatments and feed Annex I, Part A, point 8 of Regulation (EC) No 852/2004. Exempt from the HACCP duty in Article 5 Article 5(3) of Regulation (EC) No 852/2004; hazards are guided by guides to good practice Annex I, Part B, point 1 of Regulation (EC) No 852/2004.

Processing (artisan workshops, food industry). Registration or, for products of animal origin, approval Article 6(3) of Regulation (EC) No 852/2004 with the requirements of Reg. 853/2004 Article 4 of Regulation (EC) No 853/2004; structured HACCP Article 5(1) of Regulation (EC) No 852/2004; requirements for premises Annex II, Chapter I, point 2 of Regulation (EC) No 852/2004 and preparation rooms; any heat treatment Annex II, Chapter XI, point 1 of Regulation (EC) No 852/2004; microbiological criteria Article 3 of Regulation (EC) No 2073/2005; food contact materials Article 3 of Regulation (EC) No 1935/2004.

Catering (restaurants, bars, canteens, catering). Registration Article 6(2) of Regulation (EC) No 852/2004; proportionate, often simplified HACCP Article 5(2) of Regulation (EC) No 852/2004; general premises requirements Annex II, Chapter I, point 1 of Regulation (EC) No 852/2004 and personal hygiene Annex II, Chapter VIII, point 1 of Regulation (EC) No 852/2004; control of the cold chain Annex II, Chapter IX, point 5 of Regulation (EC) No 852/2004; allergen information Article 9 of Regulation (EU) No 1169/2011; training Annex II, Chapter XII, point 1 of Regulation (EC) No 852/2004.

Retail (food shops, supermarkets, e-commerce). Registration Article 6(2) of Regulation (EC) No 852/2004; requirements for foodstuffs and the cold chain Annex II, Chapter IX, point 5 of Regulation (EC) No 852/2004; traceability and withdrawal/recall Article 19 of Regulation (EC) No 178/2002; where food redistribution applies, Chapter Va Annex II, Chapter V bis, point 1 of Regulation (EC) No 852/2004; labelling Article 9 of Regulation (EU) No 1169/2011.

Transport (vehicles and containers for food). Requirements of Annex II, Chapter IV: clean receptacles and vehicles in good repair Annex II, Chapter IV, point 1 of Regulation (EC) No 852/2004, separation of goods Annex II, Chapter IV, point 3 of Regulation (EC) No 852/2004, maintenance of temperatures Annex II, Chapter IV, point 7 of Regulation (EC) No 852/2004; registration of the activity Article 6(2) of Regulation (EC) No 852/2004.

Mobile or temporary activity (food trucks, market stalls, fairs). Requirements of Annex II, Chapter III on movable and temporary premises Annex II, Chapter III, point 1 of Regulation (EC) No 852/2004; registration Article 6(2) of Regulation (EC) No 852/2004; proportionate HACCP Article 5(2) of Regulation (EC) No 852/2004; training and personal hygiene Annex II, Chapter XII, point 1 of Regulation (EC) No 852/2004.

Common errors

Frequently asked questions

Does a food truck need HACCP?

Yes. It is an activity after primary production, so it must implement HACCP-based procedures Article 5(1) of Regulation (EC) No 852/2004, proportionate to the simplicity of the activity, in addition to the Chapter III requirements for movable premises Annex II, Chapter III, point 1 of Regulation (EC) No 852/2004. See the food trucks page.

Must a farmer selling only their own fruit register?

Yes: primary production also requires registration of the establishment Article 6(2) of Regulation (EC) No 852/2004 and compliance with Annex I Annex I, Part A, point 2 of Regulation (EC) No 852/2004, but it is exempt from the HACCP duty in Article 5 Article 5(3) of Regulation (EC) No 852/2004.

When is approval needed instead of registration?

When the establishment handles products of animal origin subject to Reg. (EC) No 853/2004, or in the other cases set by national law Article 6(3) of Regulation (EC) No 852/2004. Otherwise registration is enough Article 6(2) of Regulation (EC) No 852/2004. See registration vs approval.

Does food transport have specific obligations?

Yes: Chapter IV of Annex II requires clean vehicles and containers Annex II, Chapter IV, point 1 of Regulation (EC) No 852/2004, separation of goods Annex II, Chapter IV, point 3 of Regulation (EC) No 852/2004 and maintenance of suitable temperatures Annex II, Chapter IV, point 7 of Regulation (EC) No 852/2004. The activity must still be registered Article 6(2) of Regulation (EC) No 852/2004.

Does the checklist account for national obligations?

In part: it flags the reference to national law where it exists (registration, training, penalties) and links to the country pages. Specific duties should be checked with the local competent authority.

Is the interactive version with PDF already available?

Yes: the interactive tool at the top of the page generates the checklist based on your type of activity and whether you handle products of animal origin, and lets you print it or save it as a PDF from the browser. It remains an indicative tool that does not replace a case-by-case assessment; new features are announced in the updates.

Sources

Drafting and review

ce85204 editorial team. Draft generated with AI from primary sources; editorial review assisted by AI (see methodology).