Is HACCP mandatory for a restaurant?
Yes. A restaurant is a food business and must guarantee food safety with a HACCP plan. HACCP stands for Hazard Analysis and Critical Control Points. The obligation is set out in Article 5 of Regulation 852/2004 . You comply with either your own plan or a hygiene code approved by the NVWA (Netherlands Food and Consumer Product Safety Authority), such as the code for hospitality (horeca). The NVWA puts it briefly: “Work with a food safety plan based on HACCP.” An inspection checks this.
A restaurant without a plan and without an approved code is not compliant, even if the kitchen staff follow the rules well in practice. The NVWA checks both the plan and how it is carried out.
Why does the obligation also apply to small restaurants?
The HACCP obligation applies to every business that prepares, serves or sells food. The number of guests, the number of stars or the turnover makes no difference. A bistro with ten tables or a café with a limited menu also falls under it.
What does differ is the size of the plan. A restaurant with a fixed menu of six dishes has a shorter hazard analysis than a restaurant with banqueting and an extensive buffet. The principles stay the same. You can read how to apply them to your business on the page about the 7 HACCP principles.
The two routes for a restaurant
| Route | What you do | When to choose it |
|---|---|---|
| Hygiene code for hospitality | You follow the approved code for your sector and complete the records | Your menu and way of working fit within the code |
| Own HACCP plan | You write the hazard analysis, CCPs and limit values yourself | You work with non-standard preparations, sous-vide, or a large catering section |
In practice, the hygiene code is the quickest route. An own plan gives more freedom but also more work, and the NVWA assesses it during an inspection. You can read more about the difference on hygiene code and HACCP. For a comparison with a management system such as ISO 22000, see ISO 22000 for hospitality.
What a restaurant must arrange in practice
Whichever route you take, you must show that the main risks are under control. For a restaurant, these are usually the same points:
- Receiving meat, fish, dairy and vegetables, with a temperature check on arrival
- Cooling, storing and keeping prepared dishes hot
- Separating raw and cooked food, and colour coding for chopping boards
- Allergens in dishes, on the menu and in orders
- Cleaning the kitchen, the washing up and the cold rooms
- Training staff and recording that training
To find out which of these points are CCPs in your restaurant, use the CCP decision tree. For most restaurants there are only a few: often cooking to core temperature, and holding hot or cooling after cooking.
Example: restaurant with a hygiene code
A fictional restaurant with fifteen seats, a fixed menu of eight dishes and no catering follows the hygiene code for hospitality. The business does not need to make its own hazard analysis, but it must keep the records from the code and show that it uses them.
| Part | How the restaurant fills it in |
|---|---|
| Route | Hygiene code for hospitality, approved by the NVWA |
| Additional | Own hazard analysis for the weekly raw fish special |
| Records | Goods-in check, fridge and hot-holding unit temperatures, cleaning schedule |
| Allergens | Matrix next to the menu, updated with every new dish |
| Staff | Instruction on starting work, annual refresher |
Note that the weekly special falls outside the code. That one dish needs its own justification. This is a typical point where the inspector asks follow-up questions.
What the inspector wants to see
During a restaurant inspection, the NVWA looks at three things. First, whether the route is right: a valid hygiene code or an own plan that matches what you actually do. Second, whether the records exist and are up to date. Third, whether staff know the way of working and carry it out.
Common mistakes that lead to remarks:
- Using a hygiene code but making a dish that the code does not cover
- Records with gaps, or filled in without a time or initials. The KHN (Koninklijke Horeca Nederland, Royal Dutch Hospitality Association) hygiene code requires at least one check a week for most records. If your plan says more often, you must meet that
- An allergen list on the menu that does not match the actual recipes
- Thinking that a HACCP certificate replaces the obligation. It does not. See HACCP certificate
For what the NVWA does during an inspection and which documents it asks for, read NVWA inspection on HACCP.
Next steps with HACCP for hospitality
Start with the HACCP checklist to see where your restaurant stands now. Then choose your route: the hygiene code if you fit within the standard, or the HACCP plan example if you need to write your own plan. For the records you fill in every day, see HACCP lists for hospitality.
Frequently asked questions about HACCP in restaurants
Does a restaurant need a HACCP certificate?
No. The legal requirement is a working HACCP system, with either an own plan or an approved hygiene code. A certificate is voluntary. You can read the difference on getting a HACCP certificate.
Can I work without a plan if my kitchen is clean?
No. The NVWA checks both the plan and how it is carried out. A clean kitchen without a plan or code does not meet the HACCP obligation.
How do I know if my dishes fall under the hygiene code?
Compare your way of working with the text of the code. If you prepare something the code does not describe, such as raw fish or sous-vide, add your own hazard analysis for it.
Sources
- NVWA - Working according to the HACCP system
- Regulation (EC) 852/2004 on food hygiene , Article 5 on HACCP procedures
- KHN - Hygiene code for hospitality