HACCP and food hygiene for small producers in Republika Srpska: relief and records

This article explains what applies in Republika Srpska to small food producers, rural households and food offered on the farm: whether HACCP is required, where relief exists and which records to keep.

In short

• Anyone who produces or processes food beyond primary production must run a self-control system based on good manufacturing and hygiene practice and HACCP principles. Documents and records must fit the type and size of the business (Pravilnik o higijeni hrane, Art. 6).
• Only food prepared for your own household's consumption, and direct supply of small quantities of primary products, is exempt (Art. 2).
• Small operators (a legal entity, entrepreneur or individual within the set quantities) may deviate on premises, rooms and equipment. The relief does not cover food safety itself.
• A small operator keeps records of quantity produced, product type, production date, and place and quantity delivered, and holds them for two years at the production site. Records of risk-control measures are kept for at least three years.

Who it applies to

• Everyone who produces, processes and sells food: processors of fruit, vegetables, milk and meat, bakeries, and rural tourist households serving a "domaća trpeza" (home table).
• Primary producers (farming, harvesting) need not set up HACCP, but must check hygiene conditions regularly and keep the prescribed records.
• A household preparing food only for its own consumption is outside these rules.

What to do

1. Decide whether you are a primary producer or a processor. A processor needs a self-control plan: hazards, critical control points, limits, monitoring, corrective actions and verification (Art. 6, Pravilnik o higijeni hrane). You may use good practice guides.
2. Name an employed person responsible for the self-control system (Zakon o hrani, Art. 26(2)) and plan laboratory analyses. Producers and processors prove food safety through analyses in an authorised or official laboratory, at their own cost (Art. 27(3) to (5)). Ask the inspector how this applies at small scale.
3. Check whether you qualify as a small operator: quantities and sales places are in the annexes of the Pravilnik o uslovima odstupanja. Examples from Annex 1: raw milk up to 200 l per week, sold only from a registered facility (farm, home table, local market, home delivery, local retail outlet, but not events); eggs up to 500 per week and 10,000 per year, which may also be sold at events. For other products, read your row in the annexes.
4. Before production starts, write a producer specification for each product (name, group, process description, raw materials and ingredients, declaration, sensory properties, analysis report).
5. Keep records on paper or electronically: quantity produced, product type, production date, place and quantity delivered. Primary plant producers record plant protection products and biocides used, pests and diseases, and analysis results. Livestock keepers record feed, treatments and withdrawal periods, disease and test results.
6. Keep the records. The small-operator rulebook asks for two years at the production site, and the hygiene rulebook asks for at least three years for risk-control records. Keeping them for three years is the safe choice.
7. Producing or processing food requires entry of the facility in the Centralni registar objekata koji posluju hranom (Central Register of Food Facilities; Zakon, Art. 29). Facilities under veterinary supervision are registered under veterinary rules. Confirm with the competent inspector what applies to your product before you start.
8. Draw up a sampling plan for finished food and surface swabs (Zakon o hrani, Art. 27(7)).

What the relief means in practice

• For plant-based and mixed products (Art. 23), a small operator may use the same entrance and exit with separation in time, and the changing room and toilet may be outside the building but inside the production premises. Similar relief exists for milk, beer and other groups, but it depends on the product, so read the article for yours.
• Only producers of traditional products or users of traditional methods (Art. 24) may have walls, ceilings and doors of natural materials and wooden or stone tools, with regular maintenance and cleaning.
• The relief covers premises, rooms and equipment. Clean water, temperature control and the cold chain, staff hygiene, hazard monitoring and records still apply.

Where to go

• Ministarstvo poljoprivrede, šumarstva i vodoprivrede Republike Srpske (Ministry of Agriculture, Forestry and Water Management), which runs the Central Register: vladars.rs
• The competent food inspector, through your municipality or city (Trebinje, Bileća, Gacko, Ljubinje, Nevesinje, Berkovići) or the Republička uprava za inspekcijske poslove (Republic Inspectorate), to confirm whether you count as a small operator.

Laws and sources

• Zakon o hrani (Službeni glasnik Republike Srpske br. 19/17), Art. 26 to 29
• Pravilnik o higijeni hrane (Službeni glasnik Republike Srpske br. 39/18)
• Pravilnik o uslovima odstupanja koja se odnose na subjekte u poslovanju sa hranom koji imaju mali obim proizvodnje (Službeni glasnik Republike Srpske br. 27/19)
• Pravilnik o higijeni hrane (Službeni glasnik BiH br. 4/13), state-level framework