HACCP is not a new requirement for restaurants — what is new is that it will be measured

Most of the news about the new State Program carries the same headline: "HACCP will be applied in 80% of food establishments."

I read the document very carefully. This headline is true, but on its own it creates a misleading impression. Because HACCP is not a newly introduced requirement for public catering.

First, let's clarify the fact

The Law of the Republic of Azerbaijan "On Food Safety," Article 19.3: food subjects must apply HACCP-based procedures at public catering and service facilities where food products are consumed, and must have an internal food safety control system based on these principles.

In other words, the obligation already exists.

So what does the State Program bring? In one sentence: measurement.

In my experience, the biggest difference in regulation lies between a rule being written and it starting to be measured. A rule that is written but not measured becomes formalized over time. A rule that starts being measured turns into a real operational matter.

How the program builds measurement

Four measures must be read together.

• 8.4.1 — methodological recommendations are prepared, trainings are held, and in the end the 80% target is measured. The notable point is in clause 6.1.4.4: there, "improper application of HACCP" is listed as a separate risk and its verification is envisaged. That is, not only the existence of the document but its proper application will be verified.

• 8.8.3 — a unified traceability subsystem within AQTIS. Every stage from production to the final consumer. The restaurant is the last link in this chain.

• 8.8.1 — real-time data exchange between AQTA and the Ministries of Health, Economy, Agriculture and other bodies.

• 8.8.7 — an artificial intelligence model for the analysis of risks and potential problems within AQTIS (2027–2030).

When these are placed side by side, my forecast is this: inspection priorities will not be chosen randomly. A complaint, a poisoning case and a laboratory result will be reflected in the establishment's risk profile more quickly. Those with tidy data will be inspected less often, those with messy data more often.

Note: the document does not indicate from which baseline the 80% target will be calculated. This is a matter that needs clarification.

Five things that show the system is working

As a consultant, I have seen the same picture in many establishments: there is a HACCP folder, but the logs are empty. This is what will be inspected.

• Temperature records — every day, without gaps. The most common deficiency I encounter is weekend gaps.
• Supply acceptance record — from whom, when, at what temperature, in what condition.
• Cleaning schedule — signed and real.
• Corrective action record — the problem is written down, and its solution is written down too. A log in which no problem is ever recorded is not convincing.
• Staff training — who, when, learned what.

All of these can also be kept on paper. But a digital log and an automatic temperature sensor both save time and create data ready for future AQTIS integration.

A supply document is no longer an accounting matter

When a traceability system is established, a business that cannot answer the question "where did you buy this product from" with documentation is left in a difficult position.

The invoice, the veterinary document, the batch number and the expiry date — these are the legal protection of the business. The weakest link is the supplier without documentation.

What will happen and when

• 2027–2028: methodological recommendations, training, pilot projects — the preparation period
• After 2029: measurement and reporting
• 2031–2032: evaluation of targets

Attention must also be paid to the supervisory structure: under the Order, AQTA carries out oversight of implementation and reports to the President once a year; monitoring and evaluation are carried out by the Center for Analysis of Economic Reforms and Communication.

If I were in your position, I would not wait for 2027. Today I would open the journals and look at the past week. The picture you see there is the picture the inspector will see in 2029.

The document does not bring a new burden to the sector. It separates the business that works systematically from the one that does not.