1. What Is a Certificate of Acceptability (COA)?

A Certificate of Acceptability — commonly abbreviated COA — is the legal permit issued to food premises by the local municipality’s Environmental Health Department. It confirms that the premises comply with the hygiene requirements of Regulation R638 of 2018 under the Foodstuffs, Cosmetics and Disinfectants Act 54 of 1972.

A COA is issued to a specific person at a specific premises. It is not transferable if ownership changes or if the Person in Charge changes. It does not carry a statutory expiry date, but municipalities may require re-inspection when material changes are made.

1.1 COA vs Other Permits — Don’t Confuse Them

2. Understanding Regulation R638 of 2018

Regulation R638 of 22 June 2018 was promulgated under the Foodstuffs, Cosmetics and Disinfectants Act 54 of 1972 and published in Government Gazette No. 41730. It replaced the previous Regulation R962 of 2012 and is the primary national hygiene standard governing all South African food premises.

2.1 What R638 Regulates

• Structural and hygiene standards of food premises (Regulation 5)
• Facilities on food premises (Regulation 6)
• Containers, appliances & equipment (Regulation 7)
• Display, storage & temperature of food (Regulation 8) — chilled ≤5°C, frozen ≤-18°C, hot-held ≥60°C
• Protective clothing (Regulation 9)
• Duties of the Person in Charge (Regulation 10) — mandatory accredited training
• Duties of food handlers (Regulation 11)
• Meat and meat products — butchery-specific (Regulation 12, Annexure F)
• Transport of food (Regulation 13)

📄 Download the official Regulation R638 PDF from the South African Government

3. Who Legally Needs a COA?

If your business handles, prepares, stores, serves or sells food to the public, Regulation R638 applies to you. This includes:

4. The Training Requirements — Section 10(1) Explained

This is the single most common reason COA applications fail. Regulation 10(1) creates two non-negotiable training obligations:

4.1 Section 10(1)(a) — Person in Charge Must Complete Accredited Training

The Person in Charge (PIC) is the individual responsible for daily food safety operations — typically the owner, manager or supervisor. Their name appears on the COA. A single premises may have only one PIC listed on the COA.

Section 10(1)(a) requires the PIC to complete accredited food safety training. This requirement is non-negotiable and applies across all South African municipalities, regardless of business size or type. The training certificate must be presented as part of the COA application.

4.2 Section 10(1)(b) — Food Handlers Must Receive Basic Hygiene Training

All food handlers — kitchen staff, cleaners, anyone who touches food — must receive basic food hygiene training from a registered provider. This training must be documented, appropriate, refreshed annually, and verifiable during inspection.

5. SAATCA vs HPCSA Accreditation — What’s the Difference?

When selecting food safety training, accreditation is the single most important factor for COA applications.

6. Why ASC Food Safety Training Is the #1 Choice for R638 Training

7. The Complete R638 Inspection Checklist

Use this 60+ point self-audit before your EHP arrives. Every item below is something EHPs check during real inspections across South Africa.

7.1 Premises Structure & Layout (Regulation 5)

• Walls, floors and ceilings smooth, non-absorbent, non-toxic, cleanable, dust-proof, free of open joints
• Floors non-slip; sloping to drainage points
• Adequate ventilation preventing condensation
• Lighting ≥220 lux in food prep areas; ≥110 lux in storage
• Pest-proofing: sealed gaps, fly screens, self-closing doors
• Separate areas for raw and cooked food OR documented cross-contamination controls
• Potable water supply adequate
• Drainage and wastewater compliant with local by-laws

7.2 Temperature & Storage (Regulation 8)

• Dry goods ≥150mm off floor, away from walls
• Refrigerators ≤5°C; freezers ≤-18°C
• Hot holding ≥60°C
• Raw meat stored below ready-to-eat food
• All food covered, date-marked, rotated FIFO
• No expired or spoiled food on premises
• Calibrated thermometers + temperature logs updated daily

7.3 Food Preparation & Cross-Contamination

• Preparation surfaces smooth, non-porous, easily cleanable
• Colour-coded cutting boards (raw meat/veg/ready-to-eat)
• Handwashing facilities separate from dishwashing sinks
• Soap and hand drying at every handwash point
• Sanitiser concentrations monitored (test strips)

7.4 Personal Hygiene (Regulation 9 & 11)

• Clean protective clothing (apron, hairnet, closed shoes)
• Uniforms separate from street clothing
• Handwashing signage in relevant languages
• No jewellery, false nails, nail polish (except plain wedding band)
• No eating/smoking/drinking in prep areas
• Illness-reporting procedure; sick staff excluded ≥48 hours
• Cuts covered with waterproof, brightly-coloured detectable dressings

7.5 Cleaning, Sanitation & Waste

• Written cleaning schedule displayed and followed
• Chemicals labelled, SDS available, stored separately from food
• Dishwashing achieves ≥82°C final rinse OR approved chemical sanitiser
• Refuse bins lidded, lined, cleaned daily
• External refuse area enclosed and pest-proof
• Grease trap installed and serviced where required

7.6 Pest Control

• No visible pests or evidence (droppings, insects, rodent signs)
• Active pest control contract OR documented internal programme
• Pest control records and trap maps available
• Bait stations secure, tamper-resistant, monitored

7.7 Training & Documentation (Regulation 10)

• SAATCA or HPCSA accredited training certificate for the Person in Charge
• Evidence of basic food safety training for every food handler
• Documented HACCP plan or FSMS (for medium/high-risk premises)
• Cleaning and sanitisation records
• Temperature monitoring records
• Supplier list and delivery records (traceability)
• SOPs for critical tasks
• Staff training matrix and refresher schedule

8. The 7-Step COA Application Process

9. City-Specific COA Application Guide

10. Documents Required

• Completed COA application form (from your municipality)
• Certified ID copy of the Person in Charge (within 3–6 months)
• SAATCA or HPCSA accredited training certificate for the PIC
• Training records for all food handlers
• Zoning certificate or proof of zoning
• Premises floor plan drawn to scale 1:50
• Company or close corporation registration documents
• Fire clearance certificate (where applicable)
• Copy of municipal account
• Vehicle registration numbers for food transport
• Pest control contract or records
• Waste removal contract
• Written cleaning and sanitisation schedule
• Supplier list
• Current menu (food service)

Butcheries: Additional training records in meat-related cleaning (R638 Section 6(8), Annexure F).

11. Fees & Timeline

12. Maintaining Your COA

A COA does not carry a statutory expiry date under R638. However, you are legally required to notify your local authority within 30 days if:

• The Person in Charge changes
• The premises layout is significantly altered
• Ownership of the business changes
• You relocate the premises
• You add/remove food transport vehicles
• You expand or reduce the scope of operations

Ongoing Compliance

• Update temperature logs daily
• Follow and record cleaning schedule
• Annual food handler training refreshers
• Maintain active pest control with records
• Update training certificates when staff change
• Quarterly internal food safety audits

13. Why COA Applications Get Rejected

Training-related (#1 cause):

• Person in Charge has no accredited training certificate
• Certificate from non-accredited provider
• No evidence of food handler training

Premises-related:

• Cracked/porous/non-cleanable surfaces
• Inadequate handwashing facilities
• No soap or hand drying at handwash points
• Poor lighting in prep/storage
• Visible pest activity
• Raw and cooked food stored together

Documentation-related:

• Incomplete application form
• Missing zoning certificate or building plan
• No cleaning schedule
• Expired/uncertified ID copy

14. COA Scams — How to Protect Your Business

Warning signs:

• “Inspector” arrives unannounced demanding immediate cash
• Offer of “fast-tracked” COA for upfront individual fee
• Phone calls demanding payment before inspection
• Certificate has no official municipal stamp or reference number

What legitimate EHPs do:

• Carry official identification — ask to see it
• Do NOT collect cash on premises
• Issue written notices of non-conformances
• Direct you to official municipal pay points

If you suspect a scam:

• Do not pay anything
• Ask for the inspector’s name, employee number and contact
• Report to the municipality’s EH Department
• Contact SAPS
• Call the Anti-Corruption Hotline: 0800 701 701

15. Home Kitchens, Food Trucks & Online Sellers

15.1 Home-Based Food Businesses

If you bake, cook or prepare food at home for commercial sale, you still need a COA — even if you sell via WhatsApp, Instagram, or a market stall. Your domestic kitchen must be inspected and meet R638 requirements. Your zoning certificate must confirm that operating a food business from your property is permitted.

15.2 Food Trucks and Mobile Catering

A food truck requires a COA like fixed premises, issued to the vehicle by registration number. Requirements: clean washable interior, adequate refrigeration, onboard handwashing facility, covered waste, safe water supply. Operating across multiple municipalities may require notification in each.

15.3 Online Food Sellers & Spaza Shops

If you sell food online — Instagram, WhatsApp, Yuppiechef — you need a COA for the preparation premises. ASC’s Food Safety for Informal Traders & Spaza Shops course (R879) is designed for this market.

16. Who Does NOT Need a COA?

• Businesses engaged only in hunting, fishing or trapping (no further processing)
• Handling of unprocessed agricultural crops in raw state
• Private homes preparing food for personal or charitable purposes with no commercial transaction

17. Penalties for Non-Compliance

Operating without a valid COA is a criminal offence under the Foodstuffs, Cosmetics and Disinfectants Act 54 of 1972.

• Immediate closure by an EHP — no court order required
• Criminal prosecution (fines or imprisonment)
• Prohibition orders
• Confiscation and destruction of food products
• Civil liability if a customer suffers foodborne illness

Real enforcement examples (2025): City of Tshwane closed Boxer Superstore in Atteridgeville and fined Burger King outlets for operating without valid COAs. Enforcement is accelerating nationally.

18. Frequently Asked Questions

19. Enrol Today — Get Your COA Sorted Fast

Last reviewed: 23 April 2026 · © 2026 ASC Food Safety Consultants · ASC Food Safety Training (trading as ASC Food Safety, previously ASC Consultants) · SAATCA TC No. 065 · HPCSA Accredited · FoodBev SETA 587/00337/1900 · BBBEE Level 1. This guide is educational and does not constitute legal advice. Food safety regulations may change — verify directly with your local Environmental Health Department.