Registering or approving a food business premises in Republika Srpska: who decides and the steps

Before you produce, process or sell food, the premises must be entered in the right register. For food of animal origin (milk, cheese, kajmak, meat, eggs, honey, fish) the procedure is set out in a 2022 rulebook. This applies to producers and processors in Republika Srpska, including East Herzegovina.

In short

• There are two routes: registration (entry in the Register of Premises without a prior check of hygiene conditions) and approval (a commission inspects the premises before entry in the Register of Approved Premises).
• You apply before starting work to the Ministry of Agriculture, Forestry and Water Management of RS (Ministarstvo poljoprivrede, šumarstva i vodoprivrede); the minister issues the decision.
• A registered premises gets a number in the form SPH-3-0000, and the veterinary inspection must check it within six months of entry.
• An approved premises first gets a temporary decision for 3 to 6 months, then final entry after a second inspection (including HACCP) and a veterinary control number BA-3-0000.
• Changes to your data must be reported within 30 days.

Who it applies to

Registered (article 3 of the rulebook), among others: primary production of eggs, honey and raw milk, fish, shellfish and snail farms, a premises in a private home where fresh cheese and kajmak are prepared for sale, milk collection points, butcher shops, fish shops, milk and egg vending machines, and vehicles selling food.

Exempt from registration are premises that supply the final consumer directly at the place where primary products are produced: an apiary selling all its own honey, up to 15,000 litres of cow milk and/or 5,000 litres of sheep or goat milk a year, and up to 100 eggs a day. The exemption is limited to direct sale to the final consumer at the place of production.

Approved (article 16): cold stores, slaughterhouses and cutting plants, meat processing, milk and milk product processing, egg processing, honey packing and processing, and other premises listed in the rulebook.

Fresh cheese and kajmak from a home may be sold from at most 50 litres of milk a day, from your own animals (article 10). This covers only fresh cheese and kajmak. Other kinds of cheese and other milk processing fall under approval (article 16), so check with the Ministry.

Premises registered or approved before the rulebook took effect kept their entry for no more than three years (article 25). That period ended at the end of September 2025. If you were entered under the old rules, ask the Ministry whether your entry has been brought into line.

For premises producing small quantities, the rulebook refers to a separate regulation on small producers (article 2, point 13). Ask the Ministry whether it applies to you; we did not check its content.

What to do

Registration (articles 5 and 6):

1. Submit Form 1, Application for entry in the Register of Premises, to the Ministry before starting production.
2. Attach: the decision registering your business or company (for individuals, a certificate of entry in the Register of Agricultural Holdings), proof of ownership or a lease, a description of production, and proof that the fee was paid.
3. The minister issues a registration decision and assigns the registration number.
4. The veterinary inspection checks the premises within six months. If conditions are not met, the inspector proposes revoking the decision.

Approval (articles 18 to 20):

1. Submit Form 2 to the Ministry before starting work.
2. Attach: the business registration decision, proof of ownership or lease, a description and floor plan (rooms, equipment, process flow), a description of activities and a flow diagram for each production line with capacity, a description of the self-control programme, and proof of fee payment.
3. The minister appoints a commission that inspects the premises.
4. If the general conditions are met, you receive a temporary decision (3 to 6 months) and a veterinary control number.
5. Before it expires the commission checks again the general and special conditions and HACCP. If all is in order you are entered in the Register of Approved Premises; if not, the application is refused and the number withdrawn.
6. A reconstruction that changes capacity, type or scope of activity requires approval again (article 21).

Other food (e.g. plant-based): the Law on Food (article 29) requires premises for production, processing, storage and wholesale to be entered in the Central Register of Premises at the Ministry, on a prescribed form; the minister issues a decision confirming conditions and assigns a registration number. We could not confirm the exact document list for this group, so ask the Ministry.

Deadlines and amounts

• Application: before starting work.
• Check of a registered premises: within six months of entry.
• Temporary approval: at least 3, at most 6 months.
• Reporting a change: 30 days (article 24).
• We could not confirm the fee amount; ask the Ministry.

Where to go

• Ministry of Agriculture, Forestry and Water Management of Republika Srpska, Trg Republike Srpske 1, Banja Luka: receives applications and issues decisions.
• Veterinary inspection within the Republička uprava za inspekcijske poslove (Republic Administration for Inspection Affairs): inspects premises.
• For a specific premises in Trebinje and nearby, check with your local veterinary station or the competent inspector.

Laws and sources

• Pravilnik o registraciji, odnosno odobravanju objekata za proizvodnju i promet hrane životinjskog porijekla i vođenju registara (Službeni glasnik RS br. 92/22), text copy on the RS Chamber of Commerce portal
• Zakon o hrani (Službeni glasnik RS br. 19/17), article 29, text on the website of the RS Ministry of Agriculture, Forestry and Water Management

This describes the rulebook as published on 21 September 2022 and the 2017 law; we found no amendments, but confirm with the Ministry before applying.