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Scenarios where registration may be required when providing food in the community

Guidance describing scenarios during COVID-19 where individuals providing food may need to register as a food business.

If you are providing food to the community, you may need to register with your local authority as a food business. This could include those providing meals to vulnerable citizens or NHS staff, or those operating from a home kitchen.

Food law requires the registration of activities where food is supplied on a regular and organised basis. This is required whether food is given away free or sold.

This guidance supplements guidance on community and charity food provision. If you are providing food to the community, this guidance should be read alongside food safety for community cooking. This includes advice on registration, food hygiene, allergen management, food labelling and delivery hygiene requirements. 

The examples on this page describe food activities that may require registration as a food business. It is not always clear whether community and charity food supply requires registration. 

The nature, size and regularity of activities in the community and charity sector are varied and these examples try to reflect this. They have been designed to reflect food activities and behaviour in relation to the COVID-19 pandemic. 

This is not an exhaustive list of activities that may require registration. We advise you to contact your local authority if you are unsure whether you need to register. 

Registration unlikely

Food provision in the following situation is unlikely to require registration:

Scenario one

  • Situation - A member of the public creates food boxes of shelf-stable goods, such as tinned food, and delivers them to elderly neighbours on an ad hoc basis.
  • Reason - This activity is not considered to have a degree of organisation. Shelf-stable foods are low-risk, even though in this scenario they are provided to a vulnerable group. The member of public does not need to register with their local authority.

Registration likely

Food provision in the following situations involves both continuity of activity and a degree of organisation. It would therefore require registration:

Scenario two

  • Situation - A charitable organisation uses money they have raised to order meals from local restaurants and takeaways. They collect this food and distribute it to local residents on a weekly basis. 
  • Reason - This activity is considered to have a degree of organisation and continuity. The distribution of either hot or cold meals carries an element of risk and requires organisation to ensure that meals are protected from contamination. The charitable organisation should register with their local authority.

Scenario three

  • Situation - A registered food business owner who runs a business that has been inspected and rated by the local authority, is preparing and delivering meals from their home kitchen. 
  • Reason - This activity is considered to have a degree of organisation and continuity. While registered with the local authority, operating from a home environment creates a different degree of risk within the operation. Part of the inspection assessment covers the premises itself. Therefore, if a different premises is being used by the business to prepare food, it must also be registered with their local authority.

Scenario four 

  • Situation - A community clubhouse which had previously not registered, as it only sold prepacked foods on occasion when the community club house was in use, has diversified into the handling and preparation of high-risk foods. This is for a period of weeks during the COVID-19 response.
  • Reason - This activity is considered to have a degree of organisation and continuity. The clubhouse's new operation creates a different degree of risk. The distribution of either hot or cold meals carries an element of risk and requires organisation to ensure that meals are protected from contamination. The community clubhouse should register with their local authority.