By Mthokozisi Nkosi, Food Scientist, SAATCA Registered R638:2018 Lead Implementer (SAATCA register RG003), Lead Auditor registered with Exemplar Global and IRCA, Founder of ASC Food Safety Consultants. Updated November 2026.
Short answer: a retail or wholesale bakery needs its own Certificate of Acceptability (COA) for the bakery premises, issued by the municipality in the name of a trained person in charge, and every baker, decorator, counter assistant and driver needs food safety training. If you are moving from a home kitchen into a shop, nothing carries over: R638 makes a COA non transferable between premises (regulation 3(9)(a)). The hazards that catch bakeries are not usually the bread. They are cream and custard fillings, allergens, flour pests and, once you start supplying other shops, delivery and records.
Still baking from home? Start with our post on home based and online food sellers. This post covers the next step: a bakery premises.
From home kitchen to bakery premises
You apply in writing to the local authority (regulation 3(2)) and an environmental health practitioner (EHP) inspects the premises against regulations 5 and 6. The application form in Annexure A asks what food you will make, the quantities, the number of staff and, where applicable, a layout plan at a scale of 1:50 showing each area and where the equipment stands. Draw that plan before you sign the lease. It forces you to decide where flour is stored, eggs are cracked and finished cakes wait.
Some bakery specific points in regulations 5 and 6:
- Ventilation: ovens, provers and dough mixers produce heat, steam and flour dust. Regulation 5(3)(b)(i) requires natural ventilation openings of at least 5% of the floor area, or artificial ventilation that meets the National Building Regulations.
- Lighting: at least 200 lux of artificial light, with fittings protected so that broken glass cannot fall into food (regulation 5(3)(b)(ii)). I often find an unprotected tube over the moulding bench.
- Wooden benches and boards: regulation 6(1) allows wooden blocks, boards and utensils, as long as dirt cannot build up on or in them. Old, split proving boards do not pass.
- Two basins: you need a wash up facility with hot and cold water for equipment (regulation 5(3)(c)(i)) and separate hand washing facilities with soap and disposable towels or another hygienic hand-drying method. Regulation 11(3)(h) forbids using the hand basin to clean equipment.
Where bakery food safety actually goes wrong
Fillings. Plain bread and rusks are low risk. Fresh cream, custard and cream cheese fillings are perishable, and Annexure E requires chilled perishable food to be kept at 5 °C or colder. Regulation 8(4)(b)(i) relaxes that only for food sold within four hours of preparation. A custard slice made on Friday afternoon for Saturday trade does not qualify. It belongs in a chilled display with a thermometer (regulation 6(5)(a)).
Allergens. A bakery works with most of the common allergens listed in the R146 labelling regulations: the significant cereals (R146 names wheat, including spelt, rye, barley and oats), egg, cow’s milk, soya and tree nuts, often peanuts too. R638 treats unintended allergens as contamination (regulation 5(2)(b)), and regulation 11(1)(c)(viii) requires hand washing after handling a common allergen that could cross contaminate other food. Shared mixers, piping bags and trays are where nut free orders go wrong.
What goes on the label. R146 exempts unwrapped “naked” bread from labelling (regulation 54(3)(d)) and also flour confectionery meant to be eaten within 24 hours (54(3)(j)), but in both cases the list of ingredients, including allergens, must be available at the point of sale on request. Keep a recipe sheet for every product at the till. Bread or cakes you wrap for sale to shops are prepackaged and need a full R146 label.
Pests and storage. Flour and sugar attract rodents and stored product insects. Regulation 10(3) requires effective measures against pests, and regulation 8(1) says stored food may not touch the floor or walls. Flour bags go on pallets or racks, away from the wall, with old stock used first.
Open display. Regulation 8(3) requires unwrapped ready to eat food on display to be protected from droplets, insects, dust and bare hands. Self serve bread bins need lids and tongs.
Opening a bakery? Train the person whose name goes on the COA
Regulation 10(1)(a) requires the person in charge to be trained, with accredited training where applicable, and the EHP will ask to see proof. The ASC Food Safety Practices for Persons in Charge course is on the SAATCA register for R638 Person in Charge training, is HPCSA CPD accredited and is run by a FoodBev SETA accredited training provider. It is fully online, self paced, and ends in a video proctored assessment.
About the provider: ASC Food Safety is an Exemplar Global Recognised Training Provider, with 28 of its auditor, HACCP, GMP and ISO courses recognised.
Wholesale changes the paperwork
When you start supplying coffee shops, spazas and delis, three more rules matter:
- Your delivery vehicle. Regulation 14(6)(a) says your own vehicle does not need its own COA if it carries prepacked food from your premises and a certified copy of your COA is in the vehicle. If you deliver unwrapped bread on trays, regulation 13 applies: a clean, dustproof compartment with a smooth, easy to clean surface, not shared with passengers, and food never on the floor.
- Records. Regulation 10(16) requires production and distribution records to be kept for at least 6 months after the shelf life of the product.
- Traceability and recall. Regulation 10(18) requires a traceability system and a recall procedure, and any recall must be reported to the local inspector and the National Directorate: Food Control. If plastic turns up in a loaf, you need to know which batch went to which shop.
Your COA is valid only for the nature of handling described on it (regulation 3(9)(b)). If a bread shop starts making cream cakes for wholesale, ask your EHP whether the certificate needs updating, and give written notice before changing the premises (regulation 3(6)).
Who in a bakery needs which course
- Owner or production manager named on the COA: the Persons in Charge course.
- The baker who opens at 3am: the early shift starts long before the owner arrives, so train that lead as a person in charge too. Team seats are 5 for R7 645 or 10 for R14 440.
- Bakers, confectioners and cake decorators: the Basic Food Safety Practices for Food Handlers course.
- Counter staff, cleaners and drivers: at least the Basic Food Hygiene Awareness course (R420, about 4 hours).
The reasoning is in who needs which course. Before you apply, work through the COA application checklist and the municipal COA guide.
Questions bakers ask
Can my bakery COA also cover my home kitchen, where I still do wedding cakes? No. A COA is tied to one premises. If you keep producing at home for sale, that kitchen needs its own certificate, or move all production into the bakery.
I bought an existing bakery with a COA on the wall. Can I keep trading on it? No. The certificate is in the previous person in charge’s name. See why a COA does not transfer to a new owner.
Training your bakers first? See the food handler course.
