HACCP for Mobile Coffee Carts: A Complete EU Compliance Guide
Essential HACCP guide for Mobile Coffee Carts owners in the EU. Learn about specific hazards, CCPs, and how to comply with EC 852/2004.

Introduction
One of the most frequent issues I encounter during audits of mobile coffee carts is the improper handling of milk. I've seen milk left in jugs at ambient temperatures for entire shifts, topped up with fresh milk, which creates a breeding ground for Bacillus cereus. This not only compromises food safety but also puts your customers at risk.
What You'll Learn
- How to manage milk temperatures effectively to prevent spoilage.
- The importance of allergen labeling and food storage practices.
- Key cleaning and hygiene protocols specific to mobile coffee carts.
What Auditors Check First
- Milk storage practices, especially temperatures and the duration milk sits at ambient.
- Hand hygiene facilities, ensuring a functional handwash station is available.
- Labeling of pre-made sandwiches and pastries, focusing on use-by dates and allergen information.
Hazards Specific to Mobile Coffee Carts
Biological Hazards
Key pathogens include Bacillus cereus, Staphylococcus aureus, and Listeria monocytogenes. Bacillus cereus can thrive when milk is held at ambient temperatures, especially dangerous in warm weather. Staphylococcus aureus spreads through hand contact during food prep, particularly with cakes and pastries.
On a busy Saturday when milk jugs are left out for the entire shift, the temperature can easily rise above 5°C. Discard any milk that has been at ambient temperature for more than 2 hours; do not mix old and new milk. Maintain fresh milk temperature below 5°C until steaming.
Chemical Hazards
Common chemical hazards include allergens in pre-made sandwiches and cakes, such as gluten, milk, egg, and nuts. Ensure that all food items have clear allergen information as required by Regulation 1169/2011 Art. 44. Failure to label can lead to severe allergic reactions.
On a busy Saturday when multiple food items are sold, check that all pre-made sandwiches have use-by labels and allergen declarations. Any item without proper labeling must be removed from sale immediately to prevent allergic reactions.
Physical Hazards
Physical hazards can include foreign objects in food, such as pieces of packaging or dirt from unsealed containers. Moulds can grow on baked goods displayed in non-sealed containers exposed to ambient air and dust. Ensure that all food items are protected from contamination.
On a busy Saturday when baked goods are displayed, check that all items are kept in sealed containers. If any baked goods show signs of mould, discard them immediately to prevent customer illness.
Seasonal Considerations
In summer, milk spoils faster; monitor milk closely and discard any that has been at ambient temperature for over 2 hours. Limit the display of cream-filled pastries and cakes to 4 hours at ambient temperature, using a time log to track this. In winter, ensure that your water system does not freeze overnight by draining it or storing the cart in a heated area.
Critical Control Points
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Milk Temperature:
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Measure the temperature of fresh milk; it must stay <5°C until steaming.
Use a calibrated digital thermometer to check the milk temperature every hour.
If the temperature exceeds 5°C, discard the milk held at ambient for more than 2 hours and replace it with fresh milk.
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Food Display Temperature:
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Monitor the temperature of sandwiches and cakes; they must be displayed <5°C or limited to 4 hours at ambient.
Use a thermometer to check the display case temperature every 2 hours, and keep a log of the times.
If the temperature exceeds 5°C or the 4-hour limit is reached, discard the food items immediately.
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Water Supply:
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Ensure potable water is used for the espresso machine, handwash, and cleaning.
Check the water tank for food-grade certification and sanitise it every week.
If the tank is not food-grade or has not been sanitised, replace it immediately with a compliant tank and sanitise the system before use.
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Equipment Hygiene:
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Steam wands must be purged and wiped after every use; group heads must be backflushed daily.
Perform these tasks after each use of the espresso machine and at the end of the day.
If equipment is not cleaned as required, clean it immediately and document the action taken.
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Common Mistakes
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Mistake:
- Milk left in jugs at ambient for the entire shift. Fix: Discard any milk held at ambient for more than 2 hours and do not top up with fresh milk.
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Mistake:
- No handwash station, relying only on hand sanitiser. Fix: Install a functional handwash station with potable water, soap, and disposable towels before opening.
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Mistake:
- Pre-made sandwiches without use-by labels or allergen information. Fix: Label all pre-made sandwiches with clear use-by dates and allergen information before displaying them for sale.
Supplier management is critical for maintaining food safety in mobile coffee carts. Proper checks upon receiving deliveries help prevent contamination and ensure quality. Follow the guidelines below to keep your products safe and compliant.
Delivery Acceptance Checklist
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Milk:
- Verify delivery temperature is <5°C, check pasteurisation date, and ensure use-by date is valid.
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Pastries/Cakes:
- Check for allergen declarations and ensure they are delivered in clean, food-grade containers.
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Coffee Beans:
- Confirm best-before date and store them sealed away from moisture and odours.
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Cups and Lids:
- Ensure all are food-grade certified and suitable for hot liquids.
When to Reject a Delivery
- Milk delivered at >5°C or past the use-by date.
- Pastries/cakes without allergen information or in damaged containers.
- Coffee beans with a best-before date that has expired.
- Cups and lids that are not food-grade certified.
Daily Monitoring Checklist
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Check milk temperature:
- <5°C at all times.
- Discard milk in jugs held at ambient for >2 hours.
- Ensure display temperature for sandwiches/cakes <5°C or limit to 4 hours at ambient with time log.
- Verify handwash station is functional before opening.
- Purge and wipe steam wand after every use.
- Backflush group head daily.
- Inspect pre-made sandwiches for use-by labels and allergen info.
- Check water tank for food-grade certification and cleanliness.
What Records Auditors Expect
- Temperature logs for milk and displayed food items.
- Milk discard records for any milk held at ambient >2 hours.
- Delivery records for milk, pastries, and coffee beans, including temperature and allergen info.
- Cleaning schedules for equipment, including backflushing and steam wand maintenance.
- Staff training records, including completion of allergen training and hand hygiene protocols.
Staff Training Requirements
Baristas must be trained on the milk jug protocol: discard milk after 2 hours at ambient and never mix old and new milk. Food handlers need allergen training if selling food alongside coffee, particularly for cakes containing gluten, milk, eggs, and nuts.
Hand hygiene training is mandatory. Demonstrate the functionality of the handwash station to new staff before opening.
Conclusion
To operate a compliant mobile coffee cart, adhere to key regulatory requirements such as maintaining milk at <5°C (EC 852/2004 Annex II Ch. III), ensuring hand hygiene with a functional handwash station (EC 852/2004 Annex II Ch. VII), and providing allergen information for non-prepacked food (Regulation 1169/2011 Art.
44). Regularly monitor food display temperatures, discard milk after 2 hours at ambient temperature, and properly label pre-made sandwiches. Implementing these measures will help mitigate risks associated with pathogens like Bacillus cereus and Staphylococcus aureus.
Quick-Start Action Plan
- Check and calibrate the thermometer to ensure accurate readings for milk storage.
- Install a functional handwash station with soap and disposable towels.
- Label all pre-made sandwiches with use-by dates and allergen information.
- Inspect your water tank to confirm it is food-grade and sanitise it this week.
- Train staff on the milk jug protocol and hand hygiene practices during the next shift.
Generate your free Mobile Coffee Carts HACCP plan at ilovehaccp.com/builder - it takes under 10 minutes and covers all the points in this guide.
For practical implementation, review building-a-haccp-process-flow-diagram and identifying-critical-control-points-in-food-safety before finalizing your HACCP records.
Frequently Asked Questions
What is seasonal considerations?
What is staff training requirements?
What is further reading & tools?
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