Entering the microgreens business means you'll be producing food - so legal compliance and food safety are paramount. In the European Union, even a small urban farm must follow regulations to ensure products are safe to eat. This section will guide you through the key EU rules, registration steps, and safety best practices for running a microgreens business legally.
Registering as a Food Business Operator (FBO)
In the EU, anyone selling food is typically required to register their operation. Specifically, microgreens growers usually need to register as a Food Business Operator (FBO) with their national authority. For example, in Ireland a microgreens startup must register with the Department of Agriculture, Food and the Marine, as they are considered a primary producer of food. This registration is often a simple process (usually filling out a form notifying the authorities of your activities), but it is mandatory before you start selling. Operating without registering can have legal consequences and prevent you from selling your produce.
When you register, you are essentially agreeing to follow EU food safety laws. There is no special "microgreens license" in most cases; instead, you come under general food production and hygiene rules. It's wise to contact your local food safety authority or agriculture department to get the correct registration form and guidance. Many countries have online resources for new food businesses. Remember that registration is often free but must be done prior to any sales. It also puts you on the radar for inspections or guidance from food safety inspectors, which is a good thing - they can help ensure you are meeting requirements from day one.
EU Hygiene Regulations (EC No. 852/2004)
The cornerstone of food production law in Europe is EU Regulation (EC) No. 852/2004 on the hygiene of foodstuffs. This law requires all food businesses to maintain proper hygiene and to identify and control potential food safety hazards. For a microgreens business, practical implications are things like: keeping your growing area and equipment clean, using safe water for irrigation, and preventing any contamination of your greens. Under these rules, you should implement basic Hazard Analysis and Critical Control Points (HACCP) principles - essentially, think through the risks (e.g. seed contamination, mold growth, unclean surfaces) and have steps to control them. For instance, a common hazard with microgreens is the potential for bacteria on seeds (since microgreens are eaten raw). Your controls might include purchasing only tested, high-quality seeds and sanitizing trays between plantings.
Importantly, keep records of your safety practices. Regulators expect even small producers to document things like cleaning schedules, seed sources, and any issues that occur. While a full HACCP plan might not be legally required for very small businesses, it's good practice to have a notebook or digital log for your own protection and improvement. If you ever expand or get inspected, these records show you are diligent. The justanswer example above highlights that maintaining records of hazard controls is crucial to comply with 852/2004.
Special Rules for Sprouts and Microgreen Seeds
Microgreens occupy a gray area between sprouts and vegetables, and EU regulators have focused heavily on sprouts and seeds for sprouting after a major foodborne illness outbreak in 2011. That E. coli outbreak (linked to sprouted fenugreek seeds) led the EU to enact strict rules on traceability and safety for sprouts. While microgreens are not exactly the same as sprouts (sprouts are usually germinated in water and eaten whole, root and all), many of the risks are similar - primarily, pathogens on the seed that can multiply in warm, humid growing conditions.
As a result, it is wise (and sometimes legally required) for microgreens producers to adhere to the Commission regulations introduced in 2013 for sprouts. These include: ensuring full traceability of each seed lot (knowing and recording where your seeds came from and keeping invoices), and in some cases getting your facility approved by authorities if producing sprouts at scale. For microgreens, most countries treat them as "plants grown in soil or substrate" rather than pure sprouts, so the full sprout approval (Regulation (EU) No. 210/2013) may not apply. However, you should still follow similar safety steps:
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Buy seeds labeled for sprouting or microgreens, which often come with a certificate that they have been tested for pathogens (Salmonella, E. coli STEC, etc.).
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Implement lot identification - if you grow multiple batches, keep track of which seed lot was used for which batch, so if there ever were a problem you could trace it.
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Consider testing your irrigation water or even the output if you grow a very large amount, as an extra safety measure.
EU law also requires quick recall procedures for unsafe food. Make sure you have supplier contact info and a plan (e.g. notify customers, stop sales) should you ever find a contamination. Though such incidents are rare, being prepared is part of compliance.
National Requirements and Inspections
Each EU member state administers these food safety laws through its own agencies, so requirements can vary slightly by country:
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Registration or Licensing: As mentioned, register with the local authority. Some countries might use the term "register as a primary producer" or have a specific form for horticulture businesses.
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Inspections: Once registered, you might get a visit from a food safety inspector, especially if you produce larger quantities. They will check your growing area for cleanliness and your records. Don't be alarmed - if you follow basic hygiene (no pests, no dirt/manure near the grow area, workers washing hands, etc.), inspections can actually be helpful and educational.
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Water and Lab Testing: Some countries may require a water test (to ensure your irrigation water is potable) or encourage periodic microbial testing of your product. While not always mandatory for small farms, it can be a good practice or might be required by certain buyers (e.g. a grocery chain might ask for a lab test result for peace of mind).
For example, if you plan to sell pre-packaged microgreens in a retail setting, you'll need to follow labeling laws. The EU Food Information Regulation (1169/2011) requires proper labeling of packaged foods - product name, weight, producer address, use-by date, and any relevant storage instructions. Nutritional labeling is usually not mandatory for unprocessed products sold locally, but if you make any nutrition or health claims ("high in vitamin C" etc.), you must have evidence and adhere to specific regulations on claims.
Also, consider if you want to pursue organic certification. Microgreens can be grown organically relatively easily (since they're harvested so young, pest/disease pressure is low). Being certified organic under EU rules (Regulation (EU) 2018/848) could be a selling point, but it comes with inspection and paperwork. If your target market values organic, look into the process with your national organic certification body.
Hygiene Best Practices for Microgreen Producers
Regulations aside, maintaining top-notch hygiene will protect your customers and your business's reputation. Here are some best practices (which also keep you well within compliance of EU rules):
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Clean growing environment: Grow microgreens in a clean, enclosed area away from contaminants. If using a greenhouse or indoor room, keep pets out and minimize outside soil/dust coming in.
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Sanitize equipment: Use food-safe sanitizers (e.g. a dilute bleach solution or hydrogen peroxide) to regularly sanitize trays, scissors, misting bottles, and any surfaces that contact the microgreens. Do this between every crop cycle to prevent any bacterial build-up or mold transfer.
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Water quality: Use potable (drinkable) water for irrigation. If using tap water, that's usually fine. If using rainwater or well water, consider testing it or treating it (simple filters or UV can kill microbes). Remember microgreens are eaten raw, so water safety is crucial.
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Personal hygiene: Anyone handling the microgreens should wash hands thoroughly (and often). If you're harvesting and packing, consider wearing disposable gloves and a hairnet. At the scale of a small startup this might sound formal, but these habits prevent accidental contamination. Health authorities will expect this level of care even from small producers.
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Keep logs: Document your cleaning schedule and seed sources as mentioned. Also note any issues like if a batch developed an off smell or mold - and what you did (e.g. discarded it, cleaned the area). This helps continuously improve your process and demonstrates due diligence.
By registering your business, following EU hygiene regulations, and implementing rigorous safety practices, you'll build trust with both regulators and customers. Food safety may not be the most exciting part of the microgreens business, but it is arguably the most important. The 2011 outbreak taught Europe a hard lesson about complacency - today's rules exist to prevent the next incident. Embrace these standards as part of your brand's quality promise. By doing so, you protect consumers and create a solid foundation for your microgreens venture to grow legally and sustainably.