HACCP Requirements Under Regulation (EC) 852/2004 Explained

HACCP Requirements Under EU Regulation 852/2004

Regulation (EC) 852/2004 requires food businesses to implement procedures based on HACCP principles. The requirement is practical: identify hazards, control them effectively, and prove control with records and verification.

Search intent

Primary intent: legal/regulatory search intent.

• eu 852 2004 haccp requirements
• article 5 haccp procedures explained
• small food business obligations eu

What you will learn

• What EU 852/2004 expects from different food business models
• How HACCP-based procedures are checked in inspections
• How to document compliance without unnecessary bureaucracy

Fast answer

You need documented, implemented, and maintained HACCP-based procedures proportionate to your business risk, including hazard analysis, control measures, monitoring, corrective action, verification, and records.

Quick reference table

UK vs EU practical differences

• EU member state enforcement details can vary, but the core HACCP duty remains consistent.
• UK has retained parallel hygiene principles post-Brexit, with local implementation and authority process differences.
• Cross-border operators should maintain a harmonized core system plus local annexes where needed.

Compliance references

• Regulation (EC) 852/2004 Article 5
• Regulation (EC) 178/2002 food law principles

Common mistakes and fixes

• Mistake:
  • Treating HACCP as one-time documentation. Fix: Include review triggers for menu, process, equipment, and supplier changes.
• Mistake:
  • Missing prerequisite controls in sanitation and training. Fix: Document and verify PRPs alongside HACCP controls.
• Mistake:
  • No verification routine. Fix: Add internal checks, trend review, and management sign-off.

What auditors ask for as evidence

• HACCP-based procedures and review logPrerequisite program records:
  • cleaning, pest, water, maintenance, training
• Monitoring and corrective action records at CCPs and key controls
• Verification outcomes and improvement actions

Enforcement-style examples

• Inspectors frequently escalate where records exist but implementation on site is weak.
• Failure to review after process change is a common non-conformity.
• Weak traceability and supplier assurance can trigger wider compliance findings.

Action plan

1. Map legal obligations to your process and product profile.
2. Define HACCP and prerequisite controls with clear ownership.
3. Deploy practical logs and train teams on decision rules.
4. Run scheduled verification and document improvements.
5. Keep a ready-to-show compliance folder for inspections.

Final checklist

• HACCP procedures are documented and current
• Controls are implemented consistently on site
• Records demonstrate monitoring and action
• Verification confirms the system works

Frequently asked questions

Does 852/2004 prescribe one template?

No. It requires HACCP-based procedures, but format is up to the business if controls are effective.

Can small businesses simplify documentation?

Yes, if simplification remains proportionate and still demonstrates control of real hazards.

What do inspectors challenge most?

Plans not aligned with operations, weak verification, and poor corrective action closure.

How does this relate to UK businesses?

UK applies parallel hygiene duties under retained law with similar HACCP expectations in practice.

Related resources

• EU and UK requirements overview
• Is HACCP mandatory by country and sector
• Build a Regulation 852/2004-ready HACCP plan

Use Regulation 852/2004 as your compliance framework, then tailor controls to your real hazards and operations.