HACCP in Germany: writing the concept and keeping the logs

Who needs a HACCP concept — the small snack bar included

The legal basis is Article 5 of Regulation (EC) No 852/2004: every food business operator must put in place, implement and maintain a procedure based on the HACCP principles. There is no lower threshold by headcount, turnover or square metres. Restaurant, Imbiss, food truck, café, caterer, a kiosk selling filled rolls — as soon as food is prepared, handled or handed over, the duty applies.

What does exist is flexibility in scope. Small businesses with a limited range may keep the concept lean, and authorities accept sector guides to good hygiene practice — for example the one published by the DEHOGA hospitality association — as a basis. In practice, though, “lean” tends to turn into “none at all”, and that is the mistake: a short but genuine concept is fine, no concept is not.

The operator is personally responsible. That responsibility cannot be handed to the chef or to an external service provider — even when a consultant writes the document, the business is answerable for what happens in the kitchen.

The seven principles, in kitchen language

HACCP stands for Hazard Analysis and Critical Control Points. Behind the clumsy name are seven steps that translate into any kitchen:

• Analyse the hazards: where can things go wrong in your workflow? Bacteria in raw poultry, glass splinters, cleaning agents in food, allergens ending up in the wrong pan.
• Define the critical control points (CCP): where is a check the last line of defence? The classics: cooking through, the cold chain, hot holding.
• Set limits: at what value is it no longer acceptable? For instance a core temperature below 72 °C, or a fridge above 7 °C.
• Monitor: who measures, when, with what — and where is it written down? Without a named responsibility, every rule stays on paper.
• Define corrective actions: what happens concretely when a limit is exceeded? Cook further, move the goods, discard — and who decides.
• Verify: is the system still sound? Calibrate thermometers, read through the logs, review the concept once a year.
• Document: write all of the above down so it can be followed, and keep it. This is the point that decides an inspection.

What has to be in your concept

The concept is the written description of your business and its risks — not a form, but a document that fits your kitchen. It contains a short description of the operation (type of business, offering, number of guests, equipment), the product groups you work with, and a flow diagram from goods receipt through storage, preparation, cooking, hot or cold holding to service.

Every step carries its possible hazards, the resulting critical points, the limits, the monitoring and the corrective action. Add the prerequisite programmes that are often forgotten although they are inspected: cleaning and disinfection plan, pest monitoring, personal hygiene, training, waste handling, drinking water, maintenance of equipment.

A PDF downloaded for “restaurant” will not do when the business is a food truck with a gas installation and an ice machine. Inspectors spot generic templates immediately — usually because they list equipment or steps that do not exist here. The concept also has to be current: a new menu with raw fish, a new fridge, a changed workflow — then it needs updating.

The logs: what gets documented day to day

The concept describes what should happen. The logs prove that it does — and they are the first thing to land on the table during an inspection. Which ones you need depends on the business; this set covers most kitchens:

• Goods receipt: date, supplier, product, temperature on delivery, condition of the packaging, best-before date. Particularly important for chilled and frozen goods.
• Fridge and freezer temperatures: per unit, as a rule on every operating day. Separately for cold room, fridges and freezers.
• Cooking checks: core temperature of critical dishes, above all poultry, minced meat, fish and reheated food.
• Hot holding and cooling: temperature at service, and the timing of cooling down pre-cooked food.
• Cleaning and disinfection: what, how often, with which agent, signed off by whom.
• Frying fat: visual check or measurement, date of change.
• Deviations: every limit exceeded, together with the action taken — this field is the most valuable one in the whole system.

Temperatures: reference values for the kitchen

There is no single number covering everything: some values come from EU regulations, others from standards such as DIN 10508, others again from the manufacturer. The following are the reference values commonly used in German kitchens — in case of doubt, the product label and your authority decide:

• Frozen goods: −18 °C or colder
• Minced meat: +2 °C at most
• Poultry: +4 °C at most
• Fresh fish: on melting ice, roughly 0 to +2 °C
• Other perishable foods: +7 °C at most
• Hot holding: at least +65 °C
• Cooking through: core temperature of at least +72 °C for two minutes
• Cooling pre-cooked food: quickly — in practice below +7 °C within two hours

What the inspector actually looks at

Inspections are unannounced. The inspector walks through the kitchen — and then asks for the paperwork. In practice it is less often hygiene that stands out than documentation, and always at the same spots:

• Gaps of several weeks. Holidays, illness, pressure — and a month is missing from the log. Not documented means not checked.
• Identical values throughout. Fourteen days of exactly “4 °C” in the same handwriting and the same ink: visibly filled in the evening before, and more damaging than an honest gap.
• Never a single deviation. A year without one exceeded limit does not happen in a real kitchen. Someone who never records one either never measured or never looked.
• Missing initials. Without a signature it cannot be traced who measured — a common formal defect.
• A concept that does not match the business. The paper describes a salad bar that never existed; the fryer log is missing although the fryer runs daily.
• Missing staff instruction under the Infection Protection Act (see below).

What happens when something is missing

Minor defects end with a written notice (Mängelbericht) and a deadline to fix them. A follow-up inspection comes afterwards, and it is chargeable — the business pays the fee. If defects are not remedied or keep recurring, fines are possible; where there is an acute risk to health, the authority can close parts of the operation, or all of it, until the problem is fixed.

Exact amounts and deadlines differ by federal state and severity, so blanket figures found online are of little help. What is reliable is the direction: documentation defects are the cheapest avoidable mistake in hospitality, because fixing them costs nothing but consistency.

Two things that get confused: Belehrung and Schulung

The Belehrung under §43 of the Infection Protection Act comes first: an instruction given by the public health office (Gesundheitsamt) or an authorised body, before the first working day, costing roughly €20–35 depending on the city. The certificate itself does not expire — but the employer must repeat the instruction in-house every two years and document it. That repetition is exactly what tends to be missing.

Separate from it is the hygiene training under §4 of the German Food Hygiene Ordinance (LMHV): regular instruction in food hygiene matched to the person's job. It does not replace the Belehrung, and the Belehrung does not replace it. Both belong in your records — with date, content and the participants' signatures.

In kitchens with an international team there is a practical hurdle on top: instruction nobody understands does not do its job, no matter who signed the sheet. Train in Ukrainian, Russian, Turkish or Vietnamese and you get more than a protocol — you get the behaviour it is supposed to produce.

Paper or digital?

Paper is cheap and needs no electricity — and that is exactly where it fails. A sheet on the fridge door gets wet, disappears, is “caught up on” at the end of the month, and nobody notices a gap until the inspector finds it. The real weakness is not the sheet itself but that it demands nothing.

Digital logs have three properties paper cannot reproduce: a real timestamp (filling in later becomes visible instead of convenient), required fields — if a value passes the limit, the system asks for the corrective action instead of leaving it to memory — and multiple languages, so the kitchen assistant records in their own language while the document for the authority stays German.

That is how Servio works: your answers about the business turn into the HACCP concept as a finished document, the logs are kept on a phone — equipment and target values entered once, after that it is picking from a list — and a deviation forces the action. What the inspection wants to see, you print.