What Is HACCP, and Do You Actually Need a Plan?

Two things get conflated constantly here, and the difference decides whether you need to spend money. “You must have HACCP-based procedures” is true of almost every food business. “You must have a bespoke HACCP plan written by a consultant” is not. Here is where the line actually sits.

Last reviewed: 20 September 2026 against Article 5 of assimilated Regulation (EC) No 852/2004, GOV.UK food safety management systems guidance, and the FSA’s Safer Food, Better Business package (published 5 June 2025).

What HACCP actually is

It is a way of thinking, borrowed from manufacturing, that assumes you cannot inspect safety into food at the end — you have to build it in along the way. So you walk your process from delivery to service, ask what could go wrong at each step, decide which of those steps are genuinely make-or-break, and put a control, a check and a fix at each one.

The jargon sounds industrial because it came from industry. Translated, a critical control point is a step where if you get it wrong, the food is unsafe and nothing later will rescue it — cooking chicken, for instance. A step that merely matters, like washing salad, is important but is usually controlled by good practice rather than treated as a CCP.

Is HACCP a legal requirement?

Yes, in the form the law actually specifies. Article 5(1) of assimilated Regulation (EC) No 852/2004:

“Food business operators shall put in place, implement and maintain a permanent procedure or procedures based on the HACCP principles.”

Three words in that sentence do a lot of work. Permanent — not a folder written once for an inspection. Implement — the procedures have to be what actually happens, not what the paperwork says. And based on — the requirement is that your procedures follow the principles, not that you produce a document of a particular shape.

Article 5(3) limits this to businesses operating after primary production, so farmers and growers are outside it, with their own rules. Article 5(5) then makes room for exactly the flexibility small businesses need: it contemplates arrangements that facilitate implementation, including through guides to the application of HACCP principles. That is the legal space Safer Food, Better Business occupies.

The seven principles, in kitchen terms

GOV.UK states the principles in plain English. Here they are with what each one means when you are actually running a kitchen.

Principle 5 is the one most often missing. Businesses record temperatures diligently and have no written answer for what happens when a reading is wrong — which is the moment the system is supposed to earn its keep.

Full HACCP plan, or Safer Food, Better Business?

The honest position, for most people asking: if you run a café, a takeaway or a small care kitchen, you are very unlikely to need a consultant. You need the right SFBB pack, filled in properly, kept up to date, and matching your actual menu. A bespoke plan bought and filed does not make you compliant — the law asks for procedures you implement.

What SFBB is, and which pack you need

The FSA describes it simply: “Safer food, better business (SFBB) details the food safety management procedures for small businesses.” It was republished on 5 June 2025 and covers England and Wales, with equivalents elsewhere in the UK.

Packs are available for:

• caterers
• retailers
• Indian cuisine
• Chinese cuisine
• childminders
• residential care homes
• colleges, as teaching resources

Pick the pack that matches what you do, not the one that looks shortest. If your operation spans two — a shop with a kitchen — work from the closer match and add safe methods for the rest.

Prerequisites: what HACCP sits on top of

HACCP assumes the basics are already in place. Cleaning, personal hygiene, pest control, maintenance, supplier control, waste, structure and layout — these are prerequisites, not critical control points, and a HACCP system built on top of poor basics will not hold. If cleaning is unreliable, no amount of temperature logging fixes it. The four fundamentals are covered in our guide to food hygiene basics.

Who needs HACCP training?

The law names no qualification. What it requires is that food handlers are supervised, instructed and trained in food hygiene matters commensurate with their work activity — and that those who develop and maintain the HACCP-based procedures have had adequate training in applying the principles.

In practice that splits three ways:

Whether a Level 2 certificate is required at all is a separate and widely misunderstood question — we answer it in do I need a Level 2 food hygiene certificate.

What an inspector actually looks at

• Does a system exist, and does it match what you really do?
• Is it current? A diary last completed in March is worse than no diary, because it shows the system was abandoned.
• Are the records real? Identical temperatures every day, in the same pen, invite questions.
• What happened when something went wrong? Corrective actions recorded are a sign of a system in use, not a black mark.
• Do staff know it? An inspector will ask someone on the floor, not just the manager.

Your food safety management system feeds directly into the Food Hygiene Rating — it is one of the three things scored, alongside hygiene and structure. It is also the one most readily improved before a revisit.

Where allergens fit

Allergen management is not part of HACCP, though the two are often bundled together in conversation. Allergen duties come from food information law and are separate: what you must declare, how, and how you keep allergens out of dishes that should not contain them. Cross-contact does belong in your hazard analysis, but the declaration duties sit elsewhere. We cover them in the 14 allergens, and what you actually have to do about them.

Common mistakes

What this guide does not cover

It does not write your hazard analysis — that has to be specific to your process. It does not cover HACCP in meat plants or other approved establishments, which have additional requirements, nor third-party certification schemes such as BRCGS or SALSA, which are commercial standards rather than legal ones. SFBB as described applies to England and Wales; the other nations have equivalents.

Food safety training

Our Level 3 Food Safety course covers the principles of the HACCP system and how to implement them, including how to integrate tools such as Safer Food, Better Business — which is the training the person who owns your food safety system actually needs. Level 2 is the right level for food handlers who work to the procedures rather than write them. Both sit in our food safety course range and run as open course places and as group training at your premises for up to 12 people, and a group session can work through your own menu and your own safe methods rather than generic examples.

Deals

Food Safety Courses

Frequently asked questions

Is HACCP a legal requirement in the UK?

Yes, in the form the law specifies. Article 5(1) of assimilated Regulation (EC) No 852/2004 requires food business operators to “put in place, implement and maintain a permanent procedure or procedures based on the HACCP principles”. It applies to businesses after primary production. What it does not require is a particular document, template or piece of software.

Do I need a full HACCP plan for a small café?

Usually not. The law requires procedures based on HACCP principles, and the FSA’s Safer Food, Better Business package is designed for small businesses to meet that. A properly completed, up-to-date SFBB pack that matches your menu is what most small caterers use. Bespoke plans are for complex or novel processes, or where a customer contract demands one.

What are the seven principles of HACCP?

Identify food hazards that need to be avoided, removed or reduced; identify the critical control points; set limits for those CCPs; monitor them; put things right if a CCP is not under control; put checks in place to confirm the system works; and keep records of the system, the checks and the corrective actions.

What is a critical control point?

A step where control is essential — if it goes wrong the food is unsafe and no later step will fix it. Cooking and chilling are the usual examples. A step that merely matters, like washing salad, is generally handled by good practice rather than being treated as a CCP.

What is Safer Food, Better Business?

The FSA’s food safety management package for small businesses: a diary plus safe-method sheets built on HACCP principles. Packs exist for caterers, retailers, Indian cuisine, Chinese cuisine, childminders, residential care homes and colleges. It was republished on 5 June 2025 and covers England and Wales.

Is HACCP training a legal requirement?

No qualification is named in law. Food handlers must be trained commensurate with their work activity, and those who develop and maintain the HACCP-based procedures must have had adequate training in applying the principles. In a small business that is usually the owner or head chef, and Level 3 Food Safety is the normal route.

Does HACCP cover allergens?

Not the declaration duties. Allergen information requirements come from food information law and are separate from HACCP. Cross-contact belongs in your hazard analysis, but what you must tell customers, and how, is a different obligation.

How often should a HACCP system be reviewed?

Whenever anything changes — a new dish, a new process, new equipment, a new supplier — and periodically in any case. The requirement is for a permanent procedure that is implemented and maintained, so a system that no longer describes what you do has stopped meeting it.

Does our food safety management system affect our hygiene rating?

Yes. Confidence in management, which includes your food safety management system and records, is one of the three elements scored in a Food Hygiene Rating inspection, alongside hygiene and structure. It is often the quickest of the three to improve.

Do childminders need HACCP procedures?

Childminders registered as food businesses are food business operators, and there is a Safer Food, Better Business pack written specifically for childminders. It is proportionate to the scale of the operation rather than a manufacturing-style plan.

Sources

• Assimilated Regulation (EC) No 852/2004 on the hygiene of foodstuffs, Article 5
• GOV.UK, Food safety management systems
• FSA / GOV.UK, Safer food, better business (SFBB), published 5 June 2025

Not sure whether your current system would stand up, or who in your team needs Level 3? Call 0845 838 4643 or use the enquiry form on this page.