Hygiene code and HACCP: when is a hygiene code enough?
A hygiene code is a HACCP plan that your trade association has written for all companies in the sector. If you work according to a hygiene code approved by the NVWA (Netherlands Food and Consumer Product Safety Authority), you meet the legal HACCP obligation. You can read this on the NVWA page on hygiene codes . You do not need to write your own HACCP plan in that case.
A hygiene code is enough as long as all your activities fall within the scope of the code. If you do things that the code does not cover, you add them yourself using the 7 HACCP principles. Using a code is voluntary. Article 7 of Regulation (EC) No 852/2004 describes these guides as a tool that businesses use on a voluntary basis.
In short: you need either a hygiene code or your own HACCP plan. For most hospitality, craft and retail businesses, the hygiene code is the quickest route.
Hygiene code or your own HACCP plan: the difference
Both routes meet the law. They differ in how much work you do yourself and how much freedom you have.
| Hygiene code | Your own HACCP plan | |
|---|---|---|
| Who writes it? | Trade association | Your own company, possibly with an adviser |
| Approval | The code is approved in advance by the NVWA | The NVWA assesses your plan during an inspection or audit |
| Hazard analysis | Already done for the sector | You do it yourself |
| Limit values | Set out in the code | You set and justify them yourself |
| Record forms | Examples in the code | You design them yourself |
| Suitable for | Standard activities in the sector | Deviating products or processes |
| Costs | Purchase of the code | Your own time or an adviser |
Which hygiene codes are there?
The NVWA keeps a list of approved hygiene codes per sector. For hospitality, craft and retail, these are the most important. The code names below are Dutch titles.
| Sector | Hygiene code |
|---|---|
| Hospitality | Hygiene code for hospitality (Koninklijke Horeca Nederland) |
| Contract catering | Hygiene code for contract and in-flight catering |
| Restaurant chains | Hygiene code Stichting Overlegplatform Restaurantketens (STOR) |
| Ice cream parlours | Hygiene code for artisanal ice cream production |
| Bakeries | Hygiene code for bread and pastry bakeries |
| Supermarkets | Hygiene code CBL |
| Butchers and poulterers | Hygiene code for the butchers and poulterers trade |
| Fruit and vegetable shops | Hygiene code for the fruit and vegetable retail trade |
| Fish shops | Hygiene code for the fish retail trade |
| Childcare and small institutions | Hygiene code for small institutions in childcare, welfare and youth care |
| Care institutions | Hygiene code for care institutions, residential care and Defence |
There are also codes for transport and storage, wine, breweries, eggs, grains and farm dairy, among others. The full list is on the NVWA page working according to the HACCP system . The rules for drawing up and approving codes are in the Dutch Food Hygiene Decree (Warenwetbesluit Hygiëne van levensmiddelen) .
What is in a hygiene code?
A hygiene code follows the 7 HACCP principles, but it works them out for the work processes of your sector. You usually find:
- the work processes from purchasing to serving, with the risks for each step;
- the hygiene rules for staff, cleaning and pests;
- the limit values for cooling, heating and keeping warm;
- how often you must measure and record;
- example forms for your records.
The hygiene code for hospitality from KHN sets out, for example, that most records must be made at least once a week. According to KHN, you keep records for at least six months. Records of unchilled display of chilled products must be kept for at least one year.
When is a hygiene code not enough?
The code only covers what is in it. If part of your work falls outside it, you must work out that part yourself, with a hazard analysis and, if needed, your own critical control points (CCPs).
| Situation | What you do |
|---|---|
| All your work fits within the work processes of your code | The code is enough |
| You have a product that the code does not describe, for example sous-vide or fermenting | Work out that product with your own hazard analysis |
| You deliberately deviate from a limit value in the code | Justify your own value and record it |
| You also produce for other businesses or for retail | Check the scope of your code, and whether your client asks for a certificate |
| There is no code for your sector | Write your own HACCP plan |
A café that sells home-made preserved vegetables in jars, alongside its normal dishes, can quickly fall outside the hospitality code for that product. The rest of the business still falls under the code. Only the jars need their own work-out, as in the HACCP plan example.
Hygiene code and certification
A hygiene code is not a certificate. No auditor visits to hand you a paper. The NVWA checks whether you follow the code.
If a client asks for proof of food safety with a certificate, the hygiene code is your starting point but not your end point. You can read about the options on getting a HACCP certificate and on ISO 22000 for hospitality.
Common mistakes with the hygiene code
- Buying the code and putting it in a cupboard. The NVWA checks whether you work to it, not whether you own it.
- Not keeping records. The code sets how often you measure. Empty lists are a breach.
- Using an outdated version. Codes are revised. Always use the version that the NVWA currently approves.
- Forgetting deviating products. You must work out anything that is not in the code yourself.
Are you a restaurant and wondering whether the obligation also applies to you? The answer is on is HACCP compulsory for a restaurant. You turn the working agreements that follow from the code into kitchen rules for staff.