It is expected that the new regulations should clarify the responsibility of all food business operators to produce safely and not produce food that is not of the quality, nature or substance demanded by the consumer (already enshrined in the Food Safety Act 1990).

The main changes that will affect breweries are as follows:

1) Registration of premises

All food businesses (which for the purpose of the legislation is defined as “whether for profit or not and whether public or private, carrying out any stage of production, processing and distribution of food.”) and food operators (which for the purpose of the legislation means the natural or legal persons responsible for ensuring that the requirements of the food law are met within the food business they control) must be registered with their relevant local authority.

This should be done by all existing breweries and by all new breweries at least 28 days before commencing production. The regulation also states that any subsequent changes to the production premises or business operator must be made within 28 days of any such change.

Breweries that have already registered with their local authority do not need to re-register.

2) Hygiene Requirements (Article 4 (2) of EU Regulation 852/2004, Annex 11.)

In order to produce food safely you must ensure that where and how it is produced is hygienic. You must ensure your premises are kept clean and properly equipped. Foods must be hygienically handled. Staff must receive appropriate supervision, instruction and necessary training in food hygiene matters so that they can properly carry out their work.

You are required to put in place procedures which manage food safely within your establishment and such procedures should be managed by a system or systems based on HACCP (pronounced ‘hassap’ and means Hazard Analysis and Critical Control Points) as laid down in Article 5 (1) of EU Regulation 852/2004. The regulations point out that your procedures are based on HACCP principles but in order to base procedures on HACCP then you first need to understand what HACCP means within your brewery.

3) Guides to good practice

Article 7 -9 of EU Regulation 852/2004 provide for the development of national guidelines to good practice for hygiene and the application of HACCP by individual food sectors.