Most news about the new State Program has the same headline: "HACCP will be applied in 80% of food establishments."
I examined the document in full. This headline is accurate, but on its own it creates a false impression. Because HACCP is not a newly introduced requirement for public catering.
First, let's clarify the fact.
Law of the Republic of Azerbaijan "On Food Safety", Article 19.3: food business operators must apply HACCP-based procedures in 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 is between a rule being written and it starting to be measured. A written but unmeasured rule becomes formal over time. A rule that starts being measured, however, turns into a real operational matter.
How the Program structures measurement
Four measures should 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 indicated as a separate risk and its verification is envisaged. That is, not only the existence of the document but its correct application will be checked.
8.8.3 — a unified traceability subsystem in 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 in AQTIS for analyzing risks and potential problems (2027–2030).
When these are placed side by side, my forecast is this: inspection priorities will not be chosen randomly. Complaints, poisoning incidents and laboratory results will be reflected in an establishment's risk profile more quickly. Those with orderly data will be inspected less frequently, those with messy data more often.
Note: the document does not specify from which base the 80% target will be calculated. There are 90,000 facilities in the register. This is an issue 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 checked.
Temperature records — every day, without gaps. The most common deficiency I encounter is weekend gaps. Goods receipt records — from whom, when, at what temperature, in what condition. Cleaning schedule — signed and real. Corrective action record — the problem is written down, and the solution is written down. A log in which no problem is recorded is not credible. Staff training — who, when, learned what.
All of these can also be maintained on paper. But a digital log and automatic temperature sensor both save time and create ready data for future AQTIS integration.
Supply documentation is no longer an accounting matter
Once the traceability system is established, an establishment that cannot answer the question "where did you buy this product?" with documents is left in a difficult situation.
Invoice, veterinary document, batch number and expiry date — these are the establishment's legal protection. The weakest link is a supplier without documents.
What will happen when
2027–2028: methodological recommendations, trainings, pilot projects — preparation period After 2029: measurement and accountability 2031–2032: evaluation of targets
Attention should also be paid to the supervisory structure: according to the Order, AQTA supervises 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. In a program that is measured, the numbers go up.
If I were in your place, I would not wait for 2027. I would open the logs today and look at the last 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 distinguishes an establishment that works systematically from one that does not.