When You Need a HACCP Plan (and When You Don’t)

Short answer: You need a HACCP plan when your food operation involves genuine hazards that require structured, documented controls - processing raw proteins, extending shelf life, supplying retailers, or feeding vulnerable people. You don't need one when your operation is simple, your hazards are straightforward, and basic food safety procedures cover your risks adequately.

The food safety world has a communication problem. "HACCP" gets thrown around as if it's a single, universal requirement. It isn't. It's a specific system designed for specific situations. Using it where it's not needed wastes resources. Not using it where it is needed puts people at risk. Both mistakes are common.

This article draws a clear line between the two - so you can stop guessing and start acting on what actually applies to your business.

What you'll learn

• The exact circumstances that make a HACCP plan necessary
• Why many food businesses are over-complying (and what that costs them)
• A practical way to assess your own situation

When This Applies

A formal HACCP plan becomes necessary when the gap between "something goes wrong" and "someone gets seriously ill" is small. These are the situations where that gap is narrow enough to demand structured controls:

• Manufacturing ready-to-eat foods - products that won't be cooked again before consumption. The consumer has no safety net, so you are the last line of defence. Sandwiches, dips, prepared salads, chilled desserts - all require documented CCPs.
• Any form of shelf life extension - chilling, freezing, vacuum packing, MAP, curing, smoking. Each of these methods manages microbial growth, and each needs validated parameters to work safely.
• Supplying the retail or wholesale chain - every major UK and EU retailer requires HACCP as a minimum. Most require third-party certification (BRCGS, IFS, or FSSC 22000), which builds on HACCP as a foundation.
• Processing raw animal products - meat, poultry, fish, eggs, dairy. The Codex Alimentarius was clear:
  • HACCP was designed primarily for operations handling these materials.
• Producing food for institutional catering - NHS, schools, prisons, airlines. Contract catering for these sectors universally requires HACCP documentation, often audited quarterly.
• Any operation requiring regulatory approval - if you need an establishment number (meat plants, dairy processors, egg packers), a HACCP plan is part of the approval process.

When This Doesn't

Here's the other side of the line - and it's where most small food businesses live:

• Direct-to-consumer food service - restaurants, cafes, pubs, takeaways, canteens. You cook it, you serve it, the customer eats it. The time between production and consumption is hours, not days. Safer Food, Better Business or its equivalents are designed for you.
• Low-risk product categories - baked goods without cream fillings, confectionery, dried goods, roasted nuts, coffee, tea, shelf-stable preserves. The product characteristics themselves control the hazards.
• Simple assembly operations - making sandwiches to order, building salad bowls, mixing smoothies. You're handling ingredients, not transforming them. Allergen management and temperature control are your main concerns, and they don't require CCPs.
• Retail without processing - if you sell pre-packaged food that you didn't make, open, or modify, your food safety obligations focus on storage conditions and stock rotation, not process controls.
• Seasonal or occasional food sales - charity bake sales, school fetes, community events. Basic food hygiene applies, but no regulator expects a HACCP plan for your village fete cake stall.

Real Examples

The Co-Packer Who Had No Choice

NutriBlend produces protein bars for three different fitness brands. They receive raw ingredients, mix formulations, form bars, apply chocolate coatings, package in branded wrappers, and ship to distribution centres. Even though they're a small team of eight people, they need a comprehensive HACCP plan.

Why? They're manufacturing for third parties (who require it for their own due diligence), handling major allergens in a shared facility (requiring validated cleaning between runs), and producing shelf-stable products where water activity and packaging integrity are critical safety factors. Their HACCP plan runs to 25 pages and is audited annually under BRCGS.

The Street Food Vendor Who Didn't

Kai runs a Thai street food stall at food markets across London. He preps ingredients at a commissary kitchen in the morning, transports them in insulated containers, and cooks everything to order on-site. His food safety documentation consists of: a temperature log for his transport containers, his commissary kitchen cleaning schedule, allergen information for every dish (laminated and displayed), and his Level 3 food hygiene certificate.

At his last council inspection, the EHO complimented his documentation and gave him a 5-star rating. Nobody asked for a HACCP plan, because nobody needed to.

The Jam Maker Who Was Oversold

Helen makes artisan jams and marmalades. A consultant convinced her she needed a full HACCP plan and charged her £800 for a 35-page document. When she later spoke to her Environmental Health Officer, she was told her products (high sugar, high acid, hot-filled into sterilised jars) are inherently low-risk and that her existing documentation - recipes with pH values, a cleaning schedule, and supplier details - was more than adequate.

The £800 HACCP plan sits in a folder. Her actual food safety management happens on a laminated A3 sheet in her kitchen.

Details (If You Want to Go Deeper)

Understanding proportionality

The concept of proportionality runs through every piece of food safety legislation that matters to small businesses. Regulation 852/2004 doesn't use the word "plan" - it says "procedures." The Codex Alimentarius Committee on Food Hygiene has published specific guidance on HACCP application in small and less developed businesses, acknowledging that "the scope and nature of HACCP application will vary."

In practice, proportionality means:

• A market stall selling fresh fruit needs basic hygiene documentation
• A sandwich shop needs documented procedures based on HACCP principles
• A chilled meal producer needs a formal HACCP plan with validated CCPs
• A manufacturer supplying supermarkets needs a HACCP plan plus third-party certification

Each step up the risk ladder adds complexity to your documentation requirements. But you only climb the rungs that apply to you.

The role of your local authority

Your Environmental Health Officer is, practically speaking, the person whose opinion matters most. They're the ones who inspect your premises, assess your documentation, and assign your hygiene rating. If you're unsure whether you need a formal HACCP plan, ask them. It's literally their job, and most are happy to provide pre-inspection guidance.

A 20-minute conversation with your EHO can save you months of unnecessary work.

Future-proofing without over-engineering

If you're currently in the "don't need a plan" category but have ambitions to grow - perhaps supplying retailers or launching a packaged product line - it's worth thinking ahead. But thinking ahead doesn't mean building a HACCP plan you don't yet need. It means keeping clean records now, understanding your processes well, and knowing that when the time comes, the transition to a formal plan will be smoother because you've been disciplined about documentation from day one.

For practical implementation, review haccp-for-coffee-shops-and-cafes and haccp-for-food-trucks before finalizing your HACCP records.