No expiry date does not mean “frame it and forget it”.
Your Certificate of Acceptability Is Not Wall Art
That framed certificate in reception may look perfectly respectable – but does it still reflect the business operating behind it?
1. The situation: the certificate nobody looks at
Picture the scene.
A Certificate of Acceptability – better known as the CoA – is hanging neatly in reception. It was issued several years ago and has survived two office renovations, three food-safety managers and at least one change in company ownership.
Since it was issued, the business has:
- appointed a new person in charge;
- added a production area;
- installed new equipment;
- introduced several new products; and
- changed some of its food-handling activities.
Nobody is particularly worried, because the certificate does not appear to have an expiry date.
Then an Environmental Health Practitioner visits and asks a few uncomfortable questions:
“Who is the person named on this certificate?”
“Does this certificate cover the activities currently taking place?”
“Did you inform the municipality about the new preparation area?”
Suddenly, the attractive frame is not quite as reassuring as it seemed.
2. What does a Certificate of Acceptability actually mean?
The Certificate of Acceptability is issued in terms of the Regulations Governing General Hygiene Requirements for Food Premises, the Transport of Food and Related Matters -R638 of 22 June 2018.
Subject to the exemptions provided for in R638, food may not be handled on food premises unless a valid Certificate of Acceptability has been issued and is in force. The application must be submitted to the local authority in whose area the premises are situated. An inspector considers the application and inspects the premises before recommending whether the certificate should be issued.
A CoA is therefore not simply a registration document. It confirms that the premises were evaluated for the food-handling activities presented to the Environmental Health Practitioner and were considered acceptable in relation to the applicable premises and facilities requirements.
There are, however, a few important catches.
It is issued in the name of a person – not simply “the company”
R638 defines the person in charge as a natural person who is responsible for the food premises, or the owner of the premises, depending on the circumstances. The certificate is issued in the name of that person.
This means that having the correct company name somewhere in the file is not enough. The actual person named as responsible for the premises must still be the correct person.
It belongs to a specific premises
A CoA may not simply move with the business. R638 states that a certificate is not transferable from one person to another or from one food premises to another. Moving the operation – even if the company, products and employees remain the same—does not mean the old certificate automatically follows.
It covers specific food-handling activities
The certificate is valid for the nature of food handling described in the application and recorded on the certificate.
A business that originally applied to store and distribute sealed, prepacked foods should not assume that the same certificate automatically covers the preparation of ready-to-eat meals, repacking of bulk ingredients or manufacture of sauces.
The important question is not merely:
“Do we have a CoA?”
It is:
“Does our CoA cover the premises, person in charge and food-handling activities we have today?”
It is not a once-off approval of everything
The issue of a CoA does not exempt a business from complying with other municipal requirements or applicable legislation. It is not a replacement for zoning approval, building requirements, fire-safety requirements, business licensing or any other approval that may apply.
It also does not mean that the premises will remain acceptable forever, regardless of maintenance, hygiene or operational changes. It confirms the position assessed at the time of inspection.
3. Why should we care?
R638 does not create a general annual renewal cycle for every Certificate of Acceptability. That does not, however, mean that a certificate remains valid regardless of what changes at the business.
When the person in charge changes
When the person in charge is replaced, the local authority must be informed in writing within 30 days of the replacement. The local authority must then issue a new certificate in the name of the new person in charge, subject to the relevant provisions of R638.
Waiting until the next certification audit, customer visit or municipal inspection is not a suitable notification system.
When the premises change
Changes affecting the food premises and the requirements contained in regulations 5 and 6 must be communicated to the local authority in advance and in writing. These requirements deal with matters such as the design, construction, condition, facilities and equipment of the food premises.
Examples that should prompt a review include:
- adding or extending a production room;
- changing the factory layout;
- installing a new food-preparation area;
- moving handwashing, wash-up or sanitary facilities;
- changing ventilation or drainage;
- converting a store into a processing room; or
- introducing equipment that changes the flow of people, materials, waste or food.
Not every small repair will require a new certificate. The mistake is making a significant change first and only asking the municipality afterwards.
When food-handling activities change
The certificate is linked to the handling activities listed in the application and on the certificate. A significant new process or category of handling should therefore trigger consultation with the local authority.
The authority may require updated information, an inspection, an amended application or a new certificate, depending on the nature of the change.
When ownership or the business structure changes
Because the certificate is not transferable from person to person, a sale of the business, change in ownership or change in legal entity should not be treated as an administrative footnote.
Contact the relevant local authority and confirm what documentation or reapplication is required. Do not assume that the certificate belonging to the previous operator automatically covers the new one.
Because it forms part of your legal compliance
An outdated CoA can expose a gap in several parts of the food safety management system:
- legal and regulatory compliance;
- defined responsibility and authority;
- change management;
- premises control;
- document control; and
- communication with regulatory authorities.
It may also create an awkward situation during a customer or certification audit. A certificate displayed on the wall is not particularly useful if it names someone who left the business three years ago or covers activities that no longer resemble the current operation.
4. What should we do before Monday morning?
Action 1: Take the certificate out of its frame – figuratively, at least
Carry out an annual CoA review and repeat it whenever a significant change is proposed.
Annual Certificate of Acceptability check
☐ Does the legal entity still match?
Check that the business, ownership and company or close-corporation details supplied to the local authority remain accurate. Remember that the CoA itself is issued in the name of a natural person in charge.
☐ Is the person in charge still correct?
Compare the name on the certificate with the person who is genuinely responsible for the food premises. Do not use the name of a senior manager who has little or no operational responsibility simply because that person’s title sounds impressive.
☐ Are the listed activities still accurate?
Compare the nature of handling on the certificate and original application with what currently happens at the premises. Look specifically for new manufacturing, preparation, repacking, storage, serving or transport activities.
☐ Have the premises or processes changed?
Review extensions, new rooms, equipment installations, layout changes, additional production lines and changes to utilities or facilities. Confirm whether the local authority was informed where required.
☐ Is the certificate displayed where required?
R638 requires the CoA to be displayed in a conspicuous place on the relevant food premises for the information of the public. Where displaying it is impractical, a copy must be made available immediately when requested.
Also check:
☐ Is the premises address correct?
☐ Are any restrictions, conditions or stipulations being followed?
☐ Is the original or controlled copy legible?
☐ Can supporting applications and correspondence be found?
☐ Is the certificate included in the legal-compliance register?
Action 2: Create clear notification triggers
Add CoA considerations to the business’s change-management process.
The local authority should be contacted when there is a proposed:
- change of person in charge;
- move to another premises;
- sale or transfer of the food business;
- extension or significant alteration of the premises;
- change to food-handling activities;
- introduction of a substantially different process; or
- change that could affect the facilities required by R638.
The person approving changes should be required to answer:
“Could this change affect our Certificate of Acceptability?”
That question should be asked before the builders arrive, the equipment is installed or the new product is launched.
Action 3: Give someone ownership of the CoA
Assign responsibility for:
- reviewing the certificate annually;
- monitoring changes to the person in charge;
- communicating with the local authority;
- retaining applications, inspection reports and correspondence;
- ensuring the certificate is correctly displayed; and
- tracking any municipal actions to completion.
A calendar reminder titled “Check CoA” is more valuable than hoping somebody notices when the named person retires.
5. Let’s talk
Who is responsible for the Certificate of Acceptability in your organisation – and would that person automatically be informed if the premises, processes or person in charge changed?
That may be a useful question for your next food-safety team meeting.
6. Source and status
Regulation: Regulations Governing General Hygiene Requirements for Food Premises, the Transport of Food and Related Matters, R638 of 22 June 2018
Enabling legislation: Foodstuffs, Cosmetics and Disinfectants Act, 1972
Key section: Regulation 3 and Annexures A and B
Document status: Final regulation currently listed by the National Department of Health under food-hygiene and microbiology regulations.
Status checked: 3 August 2026
Important: Application procedures and supporting documents can differ between municipalities. Businesses should confirm the applicable process with the local authority responsible for the area in which the food premises are situated.