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Do I Need HACCP if I Only Sell Drinks? (Rules for Cold vs. Hot Beverages)

If your business only serves beverages, do you still need a HACCP plan? We explain the hygiene rules for bottled drinks, fresh juices, and milk-based coffees.

Do I Need HACCP if I Only Sell Drinks? (Rules for Cold vs. Hot Beverages)
Key Takeaway: If you only sell drinks, you may still need to implement a HACCP plan, depending on the type of beverages you offer and the risks associated with their production and handling. Understanding the regulations and guidelines set by EU Regulation 852/2004 is crucial to ensure compliance and food safety.
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Audit Tip
Keep monitoring logs dated, signed, and stored in a single place for fast inspection review.

Introduction to HACCP and EU Regulation 852/2004

The Hazard Analysis and Critical Control Points (HACCP) system is a systematic approach to identifying and controlling hazards in the food industry. In the UK and EU, food businesses are required to implement a HACCP-based system to ensure food safety, as outlined in EU Regulation 852/2004. This regulation applies to all food businesses, including those that only sell drinks.

Do I Need HACCP if I Only Sell Drinks?

The answer to this question depends on the type of drinks you sell and the risks associated with their production and handling. If you only sell pre-packaged, low-risk drinks, such as bottled water or soft drinks, you may not need a full HACCP plan. However, if you sell high-risk drinks, such as hot beverages or freshly squeezed juices, you will need to implement a HACCP plan to ensure food safety.

Cold vs. Hot Beverages: Different Risks, Different Requirements

The risks associated with cold and hot beverages are different, and therefore, the requirements for HACCP plans also differ. Cold beverages, such as soft drinks or bottled water, are generally considered low-risk, as they are less likely to support the growth of harmful bacteria. Hot beverages, on the other hand, are considered high-risk, as they can provide an ideal environment for bacterial growth.
  • Cold Beverages:
    • If you only sell cold beverages, you may not need a full HACCP plan. However, you will still need to follow good hygiene practices and ensure that your drinks are stored and handled safely.
  • Hot Beverages:
    • If you sell hot beverages, such as coffee or tea, you will need to implement a HACCP plan to ensure that your drinks are safe for consumption. This will involve identifying potential hazards, such as the risk of bacterial growth, and implementing controls to mitigate these risks.

EU Regulation 852/2004: Requirements for Drink Sellers

EU Regulation 852/2004 requires all food businesses, including those that only sell drinks, to implement a HACCP-based system to ensure food safety. The regulation sets out specific requirements for drink sellers, including:
  • Hazard Analysis:
    • You must conduct a hazard analysis to identify potential hazards associated with your drinks, such as the risk of contamination or bacterial growth.
  • Critical Control Points:
    • You must identify critical control points (CCPs) in your production process, such as the temperature at which your drinks are stored or served.
  • Control Measures:
    • You must implement control measures to mitigate the risks associated with your drinks, such as regular cleaning and sanitizing of equipment.
  • Monitoring and Verification:
    • You must monitor and verify your HACCP plan to ensure that it is working effectively and that your drinks are safe for consumption.

Conclusion

In conclusion, if you only sell drinks, you may still need to implement a HACCP plan, depending on the type of beverages you offer and the risks associated with their production and handling. Understanding the regulations and guidelines set by EU Regulation 852/2004 is crucial to ensure compliance and food safety. By following the requirements outlined in this regulation, you can ensure that your drinks are safe for consumption and that your business is compliant with the law. Save time by using the iLoveHACCP builder to generate your plan in minutes.

Further Reading & Tools

Ensure your business is fully compliant by exploring our other resources:

What you'll learn

  • How this HACCP topic applies in real-world operations
  • Common hazards and practical controls to reduce risk
  • Records and monitoring that auditors expect to see

What you'll learn

  • How this HACCP topic applies in real-world operations
  • Common hazards and practical controls to reduce risk
  • Records and monitoring that auditors expect to see
Dr. Joao
Written by
Dr. Joao
Scientific Lead & Founder
Published: Jan 13, 2026Last reviewed: 2026-02-12

Frequently Asked Questions

What is further reading & tools?
Ensure your business is fully compliant by exploring our other resources:
Why is do i need haccp if i only sell drinks? (rules for cold vs. hot beverages) important for food safety?
Understanding do i need haccp if i only sell drinks? (rules for cold vs. hot beverages) is essential for maintaining food safety standards, ensuring regulatory compliance, and protecting consumers from foodborne illnesses.

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