Published: 25.09.2026. · HACCP

Montenegro's new Food Hygiene Regulation in 2026: what businesses should check

Publisher: ConsultHQ

Montenegro has applied the new Food Hygiene Regulation (91/2026) since 7 July 2026. It covers premises, equipment, water, waste, transport, heat treatment, personal hygiene and employee training. Its current text also expressly addresses food safety culture, allergen control and food redistribution.

For restaurants, hotels, food producers and distributors, this does not mean that an existing HACCP system automatically becomes invalid.

Many core hygiene rules already applied before 2026.

However, businesses should review their systems against the current regulation, especially where documents do not cover management responsibilities, food safety culture, allergens or current staff training requirements.

Regulation 91/2026 has applied since 7 July 2026

The Government of Montenegro adopted the new Food Hygiene Regulation on 28 May 2026 under the Food Safety Law (59/2026).

It was published in the Official Gazette of Montenegro No. 91/2026 on 29 June and entered into force on 7 July 2026. Montenegro's official legal information system lists it as a current regulation.

It replaced the previous Food Hygiene Regulation and its amendments.

When reviewing HACCP and hygiene documents, businesses should therefore use the 2026 framework rather than older versions that can still be found online.

The regulation reflects the current European hygiene framework

Montenegro's Food Safety Administration says the regulation transposes Regulation (EC) 852/2004 on food hygiene, including its relevant amendments, into national law.

An important EU amendment is Regulation (EU) 2021/382.

It added provisions on three areas: allergen management, food redistribution and food safety culture.

All three also appear in the current Montenegrin framework.

For businesses, that matters more than the change in the regulation's number alone.

Food safety culture is an express requirement in the current regulation

One of the most important practical requirements is food safety culture.

The current regulation requires a food business to establish and maintain an appropriate food safety culture and be able to provide evidence of it.

This involves the responsibilities of employees and managers, awareness of food safety hazards, employee involvement, clear communication and sufficient resources for hygienic food handling.

It changes how a business should view HACCP.

It is no longer enough for only the quality team or the premises owner to maintain orderly documents.

Management must be able to show how responsibilities reach employees and how food safety is maintained in day-to-day work.

Management responsibilities are made explicit

The regulation singles out the responsibilities of those in charge.

They should communicate the division of responsibilities, maintain effective hygiene controls when changes are introduced, review controls and documentation, provide suitable training and supervision, and improve the system where applicable.

For a hotel or a larger food producer, this calls for particular attention.

Food safety should not be left to the HACCP coordinator alone.

It should be clear who in management checks whether the system actually works.

Food safety culture should match the size of the business

The regulation does not require the same arrangements from a small restaurant and a large food factory.

It expressly says that implementation should take account of the nature and size of the business, with measures and procedures adapted accordingly.

That helps prevent unnecessary administration.

A small business does not need a corporate system with ten reporting layers.

It must still be able to show that staff understand their responsibilities, receive appropriate training and know how to report a problem.

Allergen management goes beyond the menu or product label

The regulation has a specific requirement for equipment, vehicles and containers previously used for products or substances that cause allergies or intolerances.

They should not be used for food that does not contain that allergen unless they have been properly cleaned and checked for visible residues.

This follows the amendments in EU Regulation 2021/382.

For food production, it can affect changeovers between products.

For restaurants and hotels, it affects shared equipment, utensils and other food-contact surfaces.

Allergen control should therefore be more than a table next to the menu.

It belongs within the hygiene system.

Food redistribution and donation have specific rules

The current regulation has a section on food redistribution.

An operator redistributing food for donation must check that it is safe and suitable for people to eat. Depending on the product, the assessment includes shelf-life dates, packaging integrity, storage and transport conditions, and applicable traceability requirements.

This matters to hotels, retailers, producers and others wishing to donate safe, unsold food.

Donation does not remove food safety duties.

It requires a controlled assessment of the food.

Employee training remains essential

The regulation requires food handlers to be supervised, instructed and/or trained in food hygiene according to their duties.

Those who develop and maintain HACCP-based procedures need suitable training in HACCP principles. The regulation also requires compliance with national training programmes for employees in particular food sectors.

Here, the regulation connects directly with other 2026 rules.

The separate statutory personal hygiene training discussed in our other article is not the same as internal HACCP training.

A business should check both which training the law requires and which competencies its own HACCP responsibilities demand.

Personal hygiene remains a clear employee duty

The regulation requires a high standard of personal cleanliness and suitable clean clothing, including protective clothing where needed, for food handlers.

It also addresses employees with an illness or symptoms that may lead to food contamination.

Such a person should not handle food where there is a risk of direct or indirect contamination, and employees must report relevant health conditions to the food business operator.

For an employer, a written procedure alone is not enough.

Staff need to know whom to tell and when.

Food transport is part of the hygiene system

The regulation also sets out requirements for transport.

Vehicles and containers must be maintained and clean, food protected from contamination, and different loads separated where necessary. Where temperature affects product safety, transport must allow the appropriate temperature to be maintained and monitored.

That is an important point for logistics companies.

ISO 9001 does not replace sector-specific food hygiene requirements when a company stores or transports food.

Quality systems and hygiene controls should work together.

The regulation covers much more than cleaning premises

The name “Food Hygiene Regulation” might suggest that it mainly concerns cleaning.

Its scope is much wider.

The Food Safety Administration lists premises, rooms, equipment, water and energy supplies, waste, heat treatment, packaging, personal hygiene, employee training and food transport.

The regulation itself also addresses food, equipment, food redistribution and food safety culture.

A compliance review should therefore cover more than a cleaning plan and temperature logs.

Restaurants should review HACCP, allergens and training

Four areas are especially relevant to a restaurant.

First, HACCP and hygiene procedures should match the actual menu and kitchen.

Second, allergen controls should cover equipment, surfaces and working methods.

Third, staff training should reflect each person's duties.

Fourth, food safety culture should be evident: management and staff should be able to show that food safety is not one person's responsibility alone.

If a restaurant's HACCP system was written years ago and has not been seriously reviewed since, the current regulation provides a sound reason to conduct a gap analysis.

Hotels should check consistency across food and beverage operations

Hotels face more complex requirements because they may have several kitchens, restaurants, buffets, banquets and seasonal staff.

Food safety culture is particularly important here.

It is not enough for central food and beverage management to understand the system if shifts or outlets follow the same rules differently.

A hotel should review responsibilities, communication, training and documentation across its entire food and beverage operation.

Especially before the season starts.

Food producers should review process changes and allergens

For food producers, the regulation should be considered alongside the HACCP hazard analysis.

A new raw material, recipe, production line or piece of equipment can change hygiene risks.

Allergen control is particularly important where multiple products share equipment.

Food safety culture also puts greater emphasis on communication among quality, production and management teams.

Changing only the heading of a procedure is not enough.

The business should check whether its real controls meet the current framework.

Existing HACCP systems do not automatically need replacing

The regulation does not mean that every restaurant, hotel or producer must discard its existing HACCP system.

That would often be unnecessary.

The first step is to compare the current system with Regulation 91/2026.

If hygiene prerequisites, HACCP and documentation are sound, the main changes may be targeted: for example, food safety culture, allergens, training or a particular procedure.

A gap analysis is therefore a more sensible starting point than automatically rebuilding the system.

What businesses should check after 7 July 2026

A business should check whether its documentation uses the current legal framework, whether food safety culture is built into everyday practice and whether management responsibilities are clear.

Training, allergen management, transport, personal hygiene and the response to process changes also deserve review.

Businesses that redistribute or donate food should check the regulation's provisions on that activity as well.

ConsultHQ can use a HACCP and regulatory gap analysis to review the existing system against Regulation 91/2026 and the Food Safety Law 59/2026.

The aim is not to add paperwork.

It is to identify where the existing system already meets the requirements and where the current regulation calls for a real change in processes, documentation or training.

Related services: HACCP implementation, HACCP training and HACCP for hotels.

Official sources: Administration: Regulation 91/2026; regulation text; current food legislation.

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