Making cheese and dairy products on the farm in Republika Srpska: registration or approval

This article explains what is needed to legally make and sell cheese, kajmak and other dairy products from a farm in Republika Srpska. It concerns small producers, rural households and caterers who want to sell their own dairy products. The version of the rules described is the one in Službeni glasnik RS no. 92/22.

In short

• Fresh cheese and kajmak for sale may be made in a facility that is mainly a private home, from at most 50 litres of milk a day, only from animals kept on your own holding.
• Such a facility is registered (entry in the Register of Facilities) without a prior inspection. The Ministry issues a decision and a registration number of the form SPH-3-0000.
• The veterinary inspection carries out a check within six months of entry. If conditions are not met, it proposes revoking the decision.
• Processing milk into other products requires approval of the facility: a commission inspection, a provisional decision for 3 to 6 months, then HACCP and entry in the Register of Approved Facilities. The articles of the rulebook name only fresh cheese and kajmak for the registration route, but the registration form lists, under "milk processing in a household", also soft cheese, semi-hard cheese and young and aged kajmak. Confirm with the Ministry what can be registered for your product before investing.
• Producers of up to 15,000 litres of cow milk or 5,000 litres of sheep or goat milk a year who supply consumers directly at the place of production need not register that facility. This covers raw milk, not cheese. Above those limits, a facility producing raw milk is registered.

Who it applies to

Food business operators in animal-origin food: farms, entrepreneurs and legal entities whose facilities for producing and trading food of animal origin must be registered or approved. The rulebook covers facilities where food is prepared for placing on the market.

What to do

1. Decide the category. Only fresh cheese and kajmak in a residential building, up to 50 litres a day: registration. Other dairy products or larger volumes: approval. For soft and semi-hard cheeses and aged kajmak the articles of the rulebook give no clear answer, so confirm with the Ministry before investing.
2. For registration, submit to the Ministry, before starting production, Form 1 (Request for entry in the Register of Facilities) with: the decision on registration of the business, or for natural persons the certificate of entry in the Register of Agricultural Holdings; proof of ownership or a lease for the premises; a description of production; proof of payment of the fee.
3. For approval, submit Form 2 with: the decision on registration of the business; proof of ownership or lease; a description of the facility with a floor plan, equipment and production flows; a description of activities, a flow diagram and planned capacity; a description of the self-control programme; proof of fee payment.
4. For approval, the minister appoints a commission that inspects the facility. If the general hygiene conditions are met, you receive a provisional decision and a veterinary control number of the form BA-3-0000 for 3 to 6 months. Before it expires the commission checks the special conditions and the implemented HACCP. If all is in order, you are entered in the Register of Approved Facilities.
5. Raw milk must come from animals covered by the animal health protection measures under the Republika Srpska programme (arts. 9 and 10).
6. Report any change of data to the Ministry within 30 days. A reconstruction that changes capacity, type or scope of activity means a new approval.
7. Facilities registered or approved before 29 September 2022 kept their entry for at most three years from the rulebook's entry into force (art. 25). That transition period has ended, so if you hold an older entry, confirm with the Ministry that your facility is validly entered.

Deadlines and amounts

• Veterinary inspection check after registration: within 6 months of entry.
• Provisional approval: at least 3, at most 6 months.
• Reporting a change of data: 30 days.
• We could not confirm the fee amount in the source. Ask the Ministry.

Where to go

• Ministarstvo poljoprivrede, šumarstva i vodoprivrede Republike Srpske (Ministry of Agriculture, Forestry and Water Management), Veterinary Department, telephone 051/338-390 (assistant minister for veterinary affairs). Veterinary Department
• The veterinary inspection (Republička uprava za inspekcijske poslove, Republic Administration for Inspection Affairs) carries out official controls in the field.

Laws and sources

• Pravilnik o registraciji, odnosno odobravanju objekata za proizvodnju i promet hrane životinjskog porijekla i vođenju registara (Službeni glasnik Republike Srpske br. 92/22), arts. 2, 3, 5, 6, 9, 10, 16 to 21, 24, 25
• Zakon o veterinarstvu u Republici Srpskoj (Službeni glasnik Republike Srpske br. 75/17 and 63/24)