Food hygiene law comparison across countries (Italy, Germany, France, Spain)
Updated 2026-07-12 · Reviewed by: ce85204 editorial team — AI-assisted editorial review (2026-07-12)
Reg. (EC) 852/2004 imposes the same obligations across the EU — registration (Art. 6), HACCP self-control (Art. 5), training (Annex II Ch. XII) — but national implementation differs. This table compares Italy, Germany, France and Spain on registration, training, competent authorities and penalty basis.
Regulation (EC) No 852/2004 imposes the same obligations in every Member State — registration Article 6(2) of Regulation (EC) No 852/2004, HACCP self-control Article 5(1) of Regulation (EC) No 852/2004, training Annex II, Chapter XII, point 1 of Regulation (EC) No 852/2004 — but their implementation varies from country to country. The table below compares national implementation in four countries; filter the countries with the buttons.
| Dimension | Italy | Germany | France | Spain | Netherlands | Belgium | Austria | Portugal | Ireland | Poland | Sweden | Greece | Denmark | Finland | Czech Republic | Romania | Hungary | Bulgaria | Slovakia | Croatia | Cyprus | Estonia | Latvia | Lithuania | Luxembourg | Malta | Slovenia |
|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|
| Registration | Health SCIA notification to the municipal one-stop desk; approval for Reg. 853/2004 establishments. | Notification to the Land's food-control authority; approval (Zulassung) under Reg. 853/2004. | Déclaration d'activité to the DDPP; sanitary approval (agrément) for products of animal origin (Reg. 853/2004). | RGSEAA for supra-regional/export activities; regional or municipal registers for local retail. | Registration with the NVWA; approval for Reg. 853/2004 establishments. | Registration, authorisation or approval (agrément) with AFSCA-FAVV depending on the activity. | Notification to the district authority (Bezirksverwaltungsbehörde); approval under Reg. 853/2004. | Establishment registration/licensing; approval for products of animal origin (Reg. 853/2004). | Establishment registration with the relevant official agency (usually the HSE); approval under Reg. 853/2004 via DAFM. | Registration/approval (zatwierdzenie) with the district sanitary inspector; animal origin to the Veterinary Inspection; approval under Reg. 853/2004. | Establishment registration with the municipal (kommun) control authority; approval (godkännande) under Reg. 853/2004. | Establishment registration/approval; EFET coordinates controls; approval under Reg. 853/2004 for animal origin. | Establishment registration/authorisation with Fødevarestyrelsen; approval under Reg. 853/2004 for animal origin. | Registration of premises with the municipal food-control authority; approval under Reg. 853/2004 for animal origin. | Registration with the authority competent for the product type (SZPI or SVS); approval under Reg. 853/2004 via SVS. | Sanitary-veterinary registration/authorisation with the county directorate (DSVSA); approval under Reg. 853/2004 for animal origin. | Establishment registration with the county government office (food-chain safety); approval under Reg. 853/2004 for animal origin. | Establishment registration with the BFSA regional directorate; approval under Reg. 853/2004 for animal origin. | Registration with the regional veterinary and food administration (RVPS); approval under Reg. 853/2004 for animal origin. | Establishment registration with the competent authority; approval under Reg. 853/2004 (veterinary inspection) for animal origin. | Registration with the competent authority; approval under Reg. 853/2004 (Veterinary Services) for animal origin. | Establishment registration with the PTA; approval under Reg. 853/2004 for animal origin. | Establishment registration with the PVD; approval under Reg. 853/2004 for animal origin. | Registration with the VMVT territorial unit; approval under Reg. 853/2004 for animal origin. | Establishment registration with ALVA; approval under Reg. 853/2004 for animal origin. | Registration with the competent authority; approval under Reg. 853/2004 for animal origin. | Establishment registration with the UVHVVR; approval under Reg. 853/2004 for animal origin. |
| Training | Operator's duty; regional rules (duration and validity vary by region). Health booklet abolished. | Hygiene training under Annex II Ch. XII; for certain foods, instruction (Belehrung) under §43 IfSG by the health office. | In commercial catering, at least one person trained in food hygiene (arrêté 5.10.2011, 14 hours). | Training is the business's responsibility; the food-handler card was abolished (RD 109/2010). | Operator's duty; wide use of sector hygiënecodes approved by the ministry. | Operator's duty; sector self-checking guides validated by AFSCA. | Operator's duty; implemented via the LMSVG and the Länder. | Operator's duty to ensure staff training. | Operator's duty; the FSAI publishes national training guidance (skills levels). | Operator's duty; national good-practice guides (GHP/GMP). | Operator's duty; sector guidelines (branschriktlinjer) assessed by the Swedish Food Agency. | Operator's duty; EFET has organised a national food-hygiene training programme for food handlers. | Operator's duty; hygiene training of staff required for certain activities under national rules. | Operator's duty; hygieniapassi (hygiene competence certificate) for staff handling unpackaged perishable foods. | Operator's duty; national good-hygiene-practice guides. | Operator's duty; national provisions and good-practice guides. | Operator's duty; national good-practice guidance. | Operator's duty; national good-practice guidance. | Operator's duty; national good-practice guidance. | Operator's duty; national good-practice guidance. | Operator's duty; national good-practice guidance. | Operator's duty; national good-practice guidance. | Operator's duty; national good-practice guidance. | Operator's duty; national good-practice guidance. | Operator's duty; national good-practice guidance. | Operator's duty; national good-practice guidance. | Operator's duty; national good-practice guidance. |
| Competent authorities | Ministry of Health; local health authorities (ASL/ATS); NAS police. | BVL (federal); Länder food-supervision authorities. | DGAL (Ministry of Agriculture); departmental DDPP. | AESAN (state); Autonomous Communities for controls. | NVWA (Netherlands Food and Consumer Product Safety Authority). | AFSCA / FAVV (Federal Agency for the Safety of the Food Chain). | Länder and district authorities; BMSGPK and AGES at federal level. | ASAE (controls) and DGAV (veterinary and food authority). | FSAI (coordination); controls carried out by official agencies under service contract (HSE; DAFM for animal origin). | State Sanitary Inspection (Sanepid/GIS) for general food; Veterinary Inspection for animal origin. | Livsmedelsverket (national coordination); controls mostly carried out by municipalities. | EFET (Hellenic Food Authority), under the Ministry of Rural Development and Food. | Fødevarestyrelsen (Danish Veterinary and Food Administration); Smiley scheme for control transparency. | Ruokavirasto (Finnish Food Authority); controls mostly carried out by municipalities. | SZPI (Agriculture and Food Inspection Authority) for general food; SVS (State Veterinary Administration) for animal origin. | ANSVSA (integrated veterinary and food-safety authority) and county DSVSA directorates. | Nébih (National Food Chain Safety Office) and county government offices. | BFSA — Bulgarian Food Safety Agency (BABH), with regional directorates. | ŠVPS SR (State Veterinary and Food Administration) and regional RVPS; public health authority for communal catering. | Ministry of Agriculture (policy) and the State Inspectorate (Državni inspektorat) for controls. | Public Health Services (Ministry of Health) and Veterinary Services for animal origin. | PTA — Agriculture and Food Board (integrated authority). | PVD — Food and Veterinary Service (integrated authority). | VMVT — State Food and Veterinary Service (integrated authority). | ALVA — Luxembourg Veterinary and Food Administration (single authority). | Environmental Health Directorate (Ministry for Health); veterinary regulation for animal origin. | UVHVVR — Administration for Food Safety, Veterinary Sector and Plant Protection. |
| Penalty basis | Administrative penalties under Art. 6 of Legislative Decree 193/2007. | Administrative/criminal offences under the LFGB and Länder law. | Administrative and criminal penalties under the Code rural et de la pêche maritime. | Penalties under state/regional food-safety law. | Administrative and criminal penalties under Dutch food law. | Administrative and criminal penalties under Belgian federal law. | Administrative/criminal penalties under the LMSVG. | Administrative (contraordenações) and criminal penalties under Portuguese law. | Enforcement notices (improvement/closure) and criminal penalties under the FSAI Act 1998 and Irish law. | Administrative and criminal penalties under the Act on food and nutrition safety. | Sanction charges (sanktionsavgifter) and other measures under the Swedish Food Act. | Administrative measures and fines under Greek food law, enforced by EFET. | Administrative and criminal penalties under Danish food law. | Administrative measures under the Finnish Food Act (elintarvikelaki). | Administrative penalties under the Czech Act on foodstuffs. | Administrative penalties (contravenții) under Romanian law. | Food-chain supervision fine and measures under the Hungarian Food Chain Act. | Administrative penalties under Bulgarian food law. | Administrative penalties under the Slovak Act on foodstuffs. | Administrative penalties under Croatian law. | Administrative penalties under Cypriot food law. | Administrative penalties under Estonian food law. | Administrative penalties under Latvian food law. | Administrative penalties under Lithuanian food law. | Administrative and criminal penalties under Luxembourg food law. | Administrative penalties under Maltese food law. | Administrative penalties under Slovenian food law. |
The EU obligation is uniform (registration Art. 6, HACCP Art. 5, training Annex II Ch. XII); this compares only national implementation. For up-to-date detail open the country page: national rules change and each page states its verification date.
At a glance
- The obligation is European and uniform; what changes is how each country implements it (registration procedures, training rules, competent authorities, penalties).
- Compare Italy, Germany, France and Spain on the key dimensions.
- No country issues a certificate under Reg. 852/2004: that certificate does not exist in any Member State.
- National rules change: each country page states its verification date.
Commentary
How to read the comparison
The table isolates the national level while holding the common EU-law background constant. For registration what matters is the actual administrative procedure (in Italy the health SCIA, in Germany the notification to the Land, in France the déclaration d'activité, in Spain the RGSEAA or regional registers). For training what matters is who sets duration and validity: detail on the respective pages.
Using it correctly
The table is an orientation map, not a source for specific compliance: before operating in a country, open the dedicated page, check its update date and follow the linked official national sources. Where practice is uncertain or evolving we say so explicitly.
Frequently asked questions
Are HACCP obligations different from country to country?
No: the obligation to run HACCP-based self-control is set by Art. 5 of Reg. (EC) 852/2004 and is the same across the EU. What varies is the national implementation (training, controls, penalties).
Does a training certificate obtained in one country count in the others?
Not automatically. Certificates are governed nationally (in Italy even regionally): recognition in another country depends on the respective rules. There is no legally guaranteed EU-wide validity.
Why do you compare only four countries?
They are the first countries covered in depth. The comparison will be extended to other Member States; changes are published in the updates.
Sources
- EUR-Lex — Regulation (EC) No 852/2004, consolidated text 02004R0852-20210324: https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02004R0852-20210324 — accessed 2026-07-12.
- National sources: see the individual country pages (Italy, Germany, France, Spain).
Drafting and review
ce85204 editorial team. Draft generated with AI from primary sources; AI-assisted editorial review (see methodology). National rules change: the verification date on each country page prevails.