Our raw-milk production licence comes up for renewal every five years. We completed our second renewal in October 2025. It was more demanding than the first, partly because the regulatory framework has tightened since 2019 and partly because we expanded our production space in 2022, which triggered a re-inspection of the modified facility rather than a straightforward administrative renewal.
I am writing this down because when we went through the first renewal in 2019 I could not find any practical account of what was actually involved. The NVWA website describes the legal requirements. It does not tell you that the drainage assessment takes eight weeks or that your HACCP plan needs to reference specific EU Regulation articles by number.
The legal basis
Raw-milk cheese production in the Netherlands is governed by EU Regulation 853/2004 (hygiene rules for food of animal origin) as implemented by the Dutch Warenwet. For aged hard cheeses — Gouda styles aged more than 60 days — there is a derogation in 853/2004 Annex III, Section IX that permits use of raw milk provided the producer meets enhanced hygiene standards and holds a specific registration.
The 60-day aging rule is important. Our jong belegen (6 weeks) technically cannot be made from raw milk and sold commercially under this derogation — we make it from pasteurised milk. Only the belegen (16 weeks) and oud (11 months) are raw-milk cheeses. This distinction confuses visitors who read that we are a "raw-milk dairy."
The initial registration (2009)
The original registration process in 2009 involved:
- A facility inspection covering the production room, the milk intake area, the pressing room, and the cellar
- Submission of a HACCP plan covering all critical control points from milking through release
- A water quality certificate for the borehole we use for cleaning water
- Evidence of somatic cell count and total bacterial count monitoring for the herd (three months of records)
- Proof of cheesemaker training — I had completed a course at the Nordelijk Agrarisch College in Leeuwarden
The main delay in 2009 was the drainage assessment. The production room floor slope was borderline acceptable under the then-current standard. We had to resurface part of it before the inspection could proceed. That took six weeks and cost more than we had budgeted.
The 2025 renewal
For the 2025 renewal, the inspector (a different one than 2019, which meant re-explaining the layout from scratch) required everything from 2009 plus:
- Updated HACCP documentation referencing Regulation 2017/625 (the new Official Controls Regulation, which came into force after our 2019 renewal)
- A revised allergen management plan — this is new since 2019 and applies to our komijnekaas (caraway seeds are a declared allergen under EU FIC Regulation 1169/2011)
- Traceability records demonstrating batch-level linkage from individual cow to finished wheel — we already had this but the format needed updating to match the current NVWA template
- Verification of the 2022 production space extension: new floor plan, updated drainage certificate, and re-inspection of the expanded pressing room
The allergen management plan was the piece I had not anticipated. Caraway seeds are not something we buy in large quantities or store near other ingredients, but the plan still needed to document procurement source, storage conditions, and the cleaning procedure between komijnekaas and plain-curd batches. It is not complicated, but it took an afternoon to write properly and needed a solicitor's review before submission because the NVWA template asks for a legal signatory.
The ongoing monitoring burden
The permit does not just require an initial inspection. It requires:
- Monthly somatic cell count (SCC) testing of bulk tank milk, with records retained for three years. Our upper limit under the permit is 400,000 cells/mL; we typically run 150,000–220,000.
- Bimonthly total bacterial count (TBC) testing. Limit: 100,000 cfu/mL before release to cheesemaking. We test via Qlip laboratory in Deventer; turnaround is 48 hours.
- Pre-release pathogen testing on finished cheese — Listeria monocytogenes and E. coli O157 — on a sample from each batch. This is the item with the most lead time: results take 10 days, which means cheese cannot leave the cellar until the test is back.
- Annual facility inspection, unannounced.
The testing costs run to about €3,200 per year. That is not trivial for an operation our size. It is also not negotiable.
What I would tell someone starting now
Start the HACCP documentation before you approach the NVWA. The plan needs to be in place for the inspection; inspectors will ask questions about it and you need to know it well enough to answer without looking things up. Hire someone to review the HACCP plan before submission — a food safety consultant rather than a solicitor, unless you are also dealing with an allergen management component.
Budget more time than you think for the drainage and facility assessments. These are not purely administrative — a physical measurement that misses a target by two millimetres will send you back to a contractor.
Keep your SCC records impeccable from day one. The permit renewal process involves reviewing three years of monitoring data. Gaps or inconsistencies in the records create problems that are disproportionate to the underlying hygiene reality.
And: find another raw-milk producer and ask them what their experience was. The NVWA regional offices vary in how they apply the standards. The Noord-Holland office has been consistent and not unreasonable in our experience, but I have heard of more difficult interactions elsewhere.