SA Best Peanut Butter Business Plan — Regulation and Food Safety

Labelling, allergen and food safety regulation, HACCP-aligned controls and the certification a formal retail supplier must hold.

Regulation and Food Safety

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  • 4.1 Certification is a commercial requirement, not just a legal one
  • 4.2 The compliance calendar

Peanut butter manufacture sits under three overlapping regulatory regimes: food premises hygiene under Regulation R638 of 2018, mycotoxin tolerance under Regulation R.1145, and allergen labelling under R146. Peanut is a declared major allergen, which adds a second recall pathway independent of aflatoxin: an undeclared allergen in a co-packed line is as reportable as a mycotoxin exceedance.

Requirement

What it covers

Type

Regulation R.1145

Tolerance of fungus-produced toxins in foodstuffs; the aflatoxin limit of 10 parts per billion

Gating

Certificate of Acceptability

Regulation R638 of 2018; food premises hygiene, issued after inspection

Gating

Business licence

Businesses Act 71 of 1991, from the local municipality

Gating

HACCP and FSSC 22000

Food safety management; a precondition for retail listing

Gating

Allergen labelling

R146 labelling regulations; peanut is a declared major allergen

Gating

Laboratory accreditation

In-house testing supported by an accredited external laboratory

Gating

Product recall procedure

Documented, tested recall plan; National Consumer Commission notification obligations

Ongoing

Traceability

Lot-level traceability from kernel intake to despatched pallet

Ongoing

Environmental and effluent

Trade effluent permit for roasting and cleaning wastewater

Ongoing

Occupational health and safety

OHS Act; machinery, dust and noise regulations

Ongoing

Retailer audits

Customer-specific technical audits beyond the statutory minimum

Ongoing

Labour compliance

BCEA, national minimum wage of R30.23 an ordinary hour, UIF and COIDA

Ongoing

The statutory minimum is a Certificate of Acceptability and a business licence. That is not enough to sell to a retail chain. Formal retail and private label customers require HACCP-based food safety management, in practice FSSC 22000 or an equivalent scheme, plus their own technical audit. Without it the plant is limited to food service and industrial channels at materially lower prices — R48.00 and R43.50 a kilogram against R69.50 for an own-brand jar.

This is why certification appears in the pre-operational budget at R1 240 000 and in fixed costs at R720 000 a year. It is a condition of the pricing assumed in Section 3.2, not an optional overhead.

4.2 The compliance calendar

Obligation

Cycle

Consequence of lapse

Certificate of Acceptability

Inspection-based; material changes reported

Trading stops. This is a closure, not a penalty

FSSC 22000 certification

Annual surveillance audit, three-year recertification

Retail and private label listings fall away; the plant drops to food service pricing

Retailer technical audits

Per customer, typically annual

A failed audit removes a listing that cost money to obtain

Aflatoxin testing at intake and release

Every lot and every batch

The control itself. A gap in the record is a gap in the defence

Laboratory accreditation and proficiency

Continuous, with external verification

In-house results must be defensible to a regulator and to a customer

Recall procedure test

At least annually, end to end

An untested recall procedure is a document, not a capability

Allergen labelling under R146

Per stock keeping unit and per label change

An undeclared allergen is as reportable as a mycotoxin exceedance

Trade effluent permit

Periodic, with monitoring

Roasting and cleaning wastewater; municipal rejection stops production

Two of these deserve emphasis because they are commercial rather than merely legal. FSSC 22000 determines which channels the plant can sell into at all, and a lapse costs roughly R21 a kilogram on the affected volume. And the recall procedure must be tested annually end to end, because the difference between a 1 019-unit recall and a month of production is entirely a matter of whether the traceability system and the notification protocol work under pressure.