R638 for a farm stall: the COA, the training and the hazards that trip padstal owners up

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 farm stall that sells only fresh, unprocessed fruit and vegetables does not need a Certificate of Acceptability (COA). R638 exempts the packing, storage, display and sale of unprocessed agricultural crops from the COA requirement, as long as they are not sold at a local authority market (regulation 14(5)). The moment the padstal sells anything else, such as jams, rusks, pies, roosterkoek, biltong, coffee, milk or even cut fruit, it handles food and needs a COA in the name of a trained person in charge, with trained staff. Most farm stalls I visit crossed that line years ago without noticing.

Where the exemption stops

R638 defines “unprocessed” as food that has not been changed from its natural, raw state through a processing method. A crate of oranges or a bag of potatoes is unprocessed. A tub of cut pineapple, a peeled and cubed butternut or a bag of mixed salad has been processed, and so has every jar, pie and packet on your shelves.

Even under the exemption, regulation 14(5) requires good agricultural and manufacturing practice, and an inspector who finds a health hazard can order it fixed or stop the sale.

Food from someone else’s kitchen

A typical padstal sells goods from many local suppliers: the neighbour’s fig jam, a home baker’s milk tart. Regulation 10(17) makes the person in charge of your stall responsible for making sure food sold from the premises complies with the Act and its regulations, including labelling. In practice:

• Labels. Jars, bottles and bags are prepackaged food, so they need a label that meets the R146 labelling regulations. A handwritten “Tannie’s Jam” sticker is not enough.
• Supplier records. Ask each supplier for a copy of their COA and an ingredient list, and keep a record of what you received and when. Regulation 10(18) requires traceability and a recall procedure. Our post on home based and online food sellers explains what your suppliers need.
• Your own farm kitchen. If you bake pies or make jam in the farmhouse kitchen for the stall, that kitchen is a food premises too. The exemption for private homes in regulation 14(6)(b) only covers food given, without payment, to a church, an educational or amateur sports organisation, or a registered welfare or fund raising organisation to sell.

Meat and milk from the farm

This is where I see the most serious mistakes. Section 7(1) of the Meat Safety Act, 2000 says meat may only be sold if the animal was slaughtered at an abattoir. Section 7(2) allows slaughter on the farm for your own household or for cultural or religious purposes, but that meat may not be sold to anyone. Biltong and droëwors made from an animal slaughtered on the farm cannot go on the stall. Regulation 12(1)(a) of R638 says the same for food premises. Keep the abattoir invoice for every batch of biltong.

Raw milk has its own rules. The Regulations relating to Milk and Dairy Products (R1555 of 1997) set conditions for selling raw milk to consumers, including a closed container labelled “raw milk” or “unpasteurised”, and milk from a herd enrolled in the bovine tuberculosis and brucellosis schemes. If you dispense milk from a bulk tank into customers’ bottles, regulation 6(7) of R638 sets detailed tank rules, including at least two tanks and cooling to 5 °C or lower within three hours. In the fridge, Annexure E requires milk to be kept at 4 °C or colder. Talk to your environmental health practitioner (EHP) before you start.

About the provider: ASC Food Safety is an Exemplar Global Recognised Training Provider, with 28 of its auditor, HACCP, GMP and ISO courses recognised.

Roadside realities an EHP checks

Water. R638 defines water as potable water that meets SANS 241. Many farm stalls run on borehole or tank water. Have it tested, keep the result, and test again if the source changes. You also need a wash up facility with hot and cold water (regulation 5(3)(c)(i)) and a hand basin with soap and disposable towels or another hygienic hand-drying method (regulation 5(3)(d)(ii)).

Dust and flies. A gravel parking area beside a busy road puts dust on everything. Regulation 5(2)(b) requires food to be protected from dust and insects, and regulation 8(3) requires unwrapped ready to eat food on display, such as vetkoek, pies and koeksisters, to be covered and protected from bare hands.

The farm dogs. Regulation 10(10) forbids animals in any area where food is handled, except a guide or service dog in the sales area. The friendly farm dog asleep under the pie warmer is a finding.

Heat. Corrugated iron stalls get hot. Chilled perishable food must stay at 5 °C or colder (Annexure E) and each fridge needs a thermometer you can read (regulation 6(5)(a)). Pies in a warmer must be held at 60 °C or hotter.

Toilets. If customers sit down for coffee and a pie, Annexure D sets how many toilets and hand basins you need, counting staff plus the most customers eating at one time.

Who at a farm stall needs which course

• The farmer or family member who runs the stall and is named on the COA: the Persons in Charge course.
• The manager who runs weekends and school holidays: Persons in Charge as well. Team seats are 5 for R7 645 or 10 for R14 440.
• Staff who bake, cook, slice biltong or make coffee: the Basic Food Safety Practices for Food Handlers course.
• Till staff and packers who only handle produce and packed goods: at least the Basic Food Hygiene Awareness course (R420, about 4 hours).

Regulation 10(1)(d) requires training records that an inspector can see. See who needs which course for the general rules, and the municipal COA guide and COA application checklist for the application. Rural municipalities differ, so ask your municipality’s environmental health section how to submit.

Questions padstal owners ask

I only sell vegetables from my own farm. Do I need a COA? No, as long as they are unprocessed and you are not selling at a local authority market. Keep them clean, shaded and off the ground.

Can I sell my neighbour’s homemade jam? Yes, if it is properly labelled and made in a kitchen with a COA. As the person in charge of the stall, you answer for what is on your shelves.

We sell biltong from game we hunted. Is that allowed? Ask your provincial veterinary services and your EHP before you sell it. Section 7 of the Meat Safety Act restricts the sale of meat from animals not slaughtered at an abattoir, and I would not sell any meat product without written confirmation that the source is legal.

Ready to get the padstal certified? Enrol on the Persons in Charge course.