Guide

Digital HACCP in food production: from paper to records that already exist when the audit comes

What Regulation (EC) 852/2004 requires for HACCP documents and how digital records help at receiving, critical control points, lots and audits.

For a small or mid-sized food producer, HACCP is more than a plan in a folder. Regulation (EC) No 852/2004 requires operators to maintain permanent procedures based on the 7 HACCP principles and to establish "documents and records commensurate with the nature and size of the food business" that demonstrate the effective application of those measures (Art. 5(2)(g)). The operator must be able to provide the competent authority with evidence of compliance and retain records "for an appropriate period" (Art. 5(4)) [1].

Why records matter. In 2024, the EU Rapid Alert System for Food and Feed (RASFF) recorded 5,250 notifications, 12% more than in 2023 [2]. The Italian national report shows that a significant share of alerts starts from operators' own checks: 1,197 notifications (22.8%) in 2024 [3]. In other words, what the operator sees in time matters.

And waste. According to Eurostat, in 2024 the manufacture of food products and beverages generated 19% of food waste in the EU, 25 kg per inhabitant, about 11.3 million tonnes [4]. Lots checked late and mislabelled products often end up here.

Where control is lost on paper:

  • at receiving, when the lot and expiry date are copied by hand, or not at all;

  • at critical control points, when the temperature is written at the end of the shift;

  • at labelling, when there is no link between the finished lot and the raw-material lots;

  • before an audit, when documents are rebuilt.

What a digital flow looks like:

  1. Receiving: each delivery is checked against the invoice, with lot, expiry date, temperature and a photo; non-conforming goods are flagged before they enter stock.

  2. Production by technical sheet: the integrated scale compares weights with the recipe, with tare and tolerance.

  3. Critical control points: cooking, cooling and storage values are logged at the station; a value outside the limit requires a corrective action (principle e).

  4. Labels and lots: each finished lot is linked to the raw-material lots, so traceability works in both directions.

  5. Cleaning and verification: hygiene schedules are completed per area, and periodic verifications (principle f) stay in the history.

What stays with the operator. A digital tool does not replace the HACCP plan or the operator's responsibility. It helps the record exist when the work is done, not afterwards.

SiteQuilt: checklists and HACCP records, technical sheets with an integrated scale, lots and expiry, documents read automatically. Tested in production. → See the industry page

Sources: [1] Regulation (EC) No 852/2004, Art. 5 – eur-lex.europa.eu/eli/reg/2004/852/oj · [2] European Commission, Alert and Cooperation Network – Annual Report 2024 – food.ec.europa.eu · [3] Ministero della Salute, Relazione RASFF 2024 – salute.gov.it · [4] Eurostat, "Food waste in the EU: 129 kg per person in 2024", 29.09.2026 – ec.europa.eu/eurostat

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Frequently asked questions

Does a digital tool replace the HACCP plan?

No. A digital tool does not replace the HACCP plan or the operator's responsibility. It helps the record exist when the work is done, not afterwards.

What records does Regulation (EC) 852/2004 require?

Article 5 requires documents and records commensurate with the nature and size of the food business, showing that the HACCP-based procedures are applied effectively, kept for an appropriate period.

How does traceability work in a digital flow?

Each finished lot is linked to the raw-material lots recorded at receiving, so you can trace a product in both directions.

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