Yes they can, but they must register separately. Registration applies to the HAF club/organisation, not the premises. Therefore:
Each organisation must register as a separate food business.
Even if:
Each HAF provider remains legally responsible for:
The premises being registered does not cover external providers unless for example the school is making the food themselves for the club.
Yes, they should register each food operation site with the relevant local authority.
Food businesses must register each venue they are offering food at.
So if a HAF provider:
Each venue where food handling takes place is considered a venue and should be registered with the local authority where the venue is.
If a provider has:
Then they need to register those delivery sites.
However, if they:
Then additional registration may not be required but if they plate up the food on site then they’d need to register as this is classed as food handling.
To clarify, across Essex, EHO’s would expect:
All Essex districts operate under:
So the law is the same across Essex.
However, administrative processes can differ slightly between districts because food registration is handled by individual local authorities (e.g., the Basildon and Brentwood differences with being given a code).
So Brentwood issuing a code is likely an internal system reference.
Exemptions
If the HAF provider:
And all food provision is entirely managed by another registered food business (e.g. the school kitchen or contracted caterer), then the HAF provider would not be considered the a food business.
For example if:
So in this example, the HAF provider does not need to register.
They only distribute pre-packed food with no further handling
If the provider:
For example, if the HAF club serves prepacked sandwiches from a caterer (or Tesco meal deal) as long as the club are not storing them then they would not need to register (but obviously this goes against HAF guidelines).
However, if they:
Then they are handling food and registration would usually be required.
Some clubs have reported they have been told their EHO has advised them they do not need to register, this could be because:
The interpretation of what regular and organised menas
HAF is:
That generally meets the definition of “regular and organised”
However some EHOs may view HAF delivery at a venue as:
So providers need to be clear when they are filling in their registration and speaking to their EHO’s.
The activity is considered “Low Risk”
If food provision is:
An EHO may consider it sufficiently covered by the original registered business, but the organisation should get something in writing to confirm this from the EHO.
Some organisations may misinterpret the ‘selling’ of food, food for HAF is funded to technically they are ‘selling’ it but no money exchange happens with the recipients.
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