Starting a Sushi Business in the UK: Food Safety Checklist

The UK sushi market has grown significantly over the past decade, driven by consumer demand for fresh, healthy dining options. Whether you are opening a dedicated sushi restaurant, adding a sushi counter to an existing venue, or launching a sushi delivery service, the food safety requirements are exacting — and rightly so. Raw fish preparation carries inherent risks that demand rigorous controls from day one.

This checklist guides you through every food safety step required to launch a compliant sushi business in the UK. Getting these foundations right from the outset will protect your customers, satisfy regulators, and give your business the best possible start.

Registering Your Food Business

Before you serve a single piece of nigiri, you must register your food business with your local authority. This is a legal requirement under Regulation (EC) No 852/2004 (retained in UK law) and must be completed at least 28 days before you begin trading. Registration is free and cannot be refused — but failure to register is a criminal offence that can result in prosecution and a fine.

Register through your local council’s environmental health department. You will need to provide details of the premises, the nature of your food business (specify that you will be preparing and serving raw fish), and the name of the food business operator. Once registered, your premises will be scheduled for an initial inspection by an Environmental Health Officer.

Premises and Equipment Requirements

Sushi preparation demands a higher standard of premises design than many other food businesses. The key principle is separation of raw and ready-to-eat foods. Your premises should include:

• Separate preparation areas for raw fish and cooked/ready-to-eat foods. Ideally, these should be physically separated. If space constraints make this impossible, you must implement robust temporal separation with thorough cleaning and sanitising between tasks.
• Adequate refrigeration — separate fridges (or clearly designated shelves) for raw fish, cooked ingredients, and vegetables. Raw fish must always be stored below cooked and ready-to-eat items. Temperature should be maintained at 0°C to 5°C.
• Dedicated handwash basins — at least one in each food preparation area, supplied with hot and cold running water, antibacterial soap, and disposable paper towels.
• Appropriate ventilation — mechanical extraction for cooking areas, and adequate natural or mechanical ventilation throughout.
• Pest-proofing — self-closing doors, mesh screens on windows, sealed gaps around pipework, and a pest control contract with a certified provider.
• A commercial-grade freezer capable of reaching -20°C or below if you intend to freeze fish in-house for parasite control.

Your HACCP Plan

A documented HACCP (Hazard Analysis and Critical Control Points) plan is a legal requirement for all UK food businesses under Regulation (EC) 852/2004. For a sushi business, your HACCP plan must be specific to the hazards associated with raw fish preparation. A generic restaurant HACCP plan will not suffice.

Your sushi HACCP plan should identify and control the following critical control points:

• Supplier verification and freezing certification for raw fish
• Delivery temperature checks
• Cold chain maintenance during storage
• Sushi rice acidification (pH 4.6 or below)
• Cross-contamination prevention during preparation
• Allergen management
• Time and temperature controls for displayed sushi

Your HACCP plan must be in place from day one — not something you develop after opening. Our HACCP consulting service can build a bespoke sushi-specific HACCP plan tailored to your premises, menu, and workflow.

Staff Training Requirements

Under Regulation (EC) 852/2004, Chapter XII, food business operators must ensure that food handlers receive training commensurate with their work activities. For sushi businesses, this means your team needs more than a generic Level 2 food safety certificate.

At a minimum, all staff who handle food should hold a Level 2 Food Safety qualification and have completed allergen awareness training. Sushi chefs and those directly involved in raw fish preparation should additionally complete specialist training that covers parasite hazards, rice acidification, raw fish handling protocols, and the specific HACCP controls relevant to sushi and sashimi. Our Sushi and Sashimi Food Safety Course is designed specifically for this purpose. All training must be documented and records retained for EHO inspection.

Sourcing Raw Fish Safely

Your choice of fish supplier is one of the most critical decisions you will make as a sushi business owner. You must source raw fish from approved suppliers who can provide:

• Freezing certificates confirming the fish has been frozen to -20°C for 24 hours or -35°C for 15 hours to destroy parasites.
• Full traceability — species identification, catch area or farm of origin, and batch numbers.
• Temperature-controlled delivery — fish should arrive at the correct temperature (frozen or chilled to between 0°C and 2°C for thawed product).

Check every delivery on arrival: verify the temperature with a calibrated probe, inspect the condition of packaging and the fish itself, and file the delivery note with the corresponding freezing certificate. Reject any delivery that does not meet your specification.

Allergen Compliance

Sushi menus are a minefield for allergens. Common ingredients include fish, crustaceans, soy (from soy sauce), sesame (in seeds and oil), wheat (in soy sauce and tempura batter), eggs (in some mayonnaise-based sauces), and molluscs. Under UK food law, you must inform customers about the presence of any of the 14 major allergens in your dishes.

For dine-in and takeaway, you may provide allergen information verbally (with a written notice directing customers to ask), in writing on the menu, or through a separate allergen matrix. However, if you sell prepacked for direct sale (PPDS) sushi — items wrapped or packaged on the premises before a customer selects them — Natasha’s Law requires a full ingredients list with allergens emphasised in bold on the label. This applies to sushi boxes prepared in advance for display, grab-and-go counters, and delivery orders packed before the customer’s specific order is placed.

Insurance and Record Keeping

Whilst not a strict food safety requirement, appropriate insurance is essential for any sushi business. You should hold:

• Public liability insurance — covering claims from customers or visitors who are injured or become ill on your premises.
• Product liability insurance — specifically covering claims arising from foodborne illness. This is particularly important for sushi businesses given the inherent risks of raw fish.
• Employers’ liability insurance — a legal requirement if you employ staff.

On the record-keeping side, you must maintain and be able to produce on demand: your HACCP plan and associated monitoring records (temperature logs, cleaning schedules, corrective actions), staff training records, freezing certificates, supplier documentation, allergen information, and pest control reports. Good records are the backbone of a high food hygiene rating. Read our guide on how to create a food safety management system for your restaurant for a comprehensive overview.

Your First EHO Inspection

After you register your food business, an Environmental Health Officer will visit to carry out an initial inspection — typically within a few weeks of opening. This first inspection is critically important because your food hygiene rating will be published on the Food Standards Agency website for the public to see. A poor initial score can deter customers before your business has had a chance to establish itself.

The EHO will assess three areas: hygienic food handling (including your raw fish controls), structural compliance of the premises, and confidence in management (your HACCP plan, training records, and overall food safety systems). For a sushi business, expect detailed questions about your freezing procedures, supplier verification, rice acidification protocol, and allergen management. Our food safety consulting service includes pre-opening audit support to ensure you are fully prepared.

Frequently Asked Questions

Do I need a food licence to sell sushi in the UK?

No, there is no specific “food licence” required to sell sushi in the UK. However, you must register your food business with your local authority at least 28 days before you begin trading. Registration is free and is a legal requirement under the Food Safety Act 1990 and Regulation (EC) 852/2004. You do not need to wait for approval — registration cannot be refused — but you must register before you start operating. Failure to register is a criminal offence.

What qualifications do sushi chefs need in the UK?

There is no legally mandated qualification specifically for sushi chefs. However, the law requires that food handlers receive training commensurate with their duties. In practice, this means sushi chefs should hold a minimum of a Level 2 Food Safety in Catering certificate, plus specialist training covering the hazards specific to raw fish preparation — including parasite control, rice acidification, cold chain management, and allergen handling. Documented training records are essential for demonstrating compliance during EHO inspections.

How much does a HACCP plan cost for a sushi business?

The cost of a professionally written HACCP plan varies depending on the complexity of your menu, the size of your premises, and the number of critical control points. For a sushi business, expect to invest more than you would for a standard restaurant because the hazard analysis is more complex. However, this is not an area to cut corners — an inadequate HACCP plan is worse than none at all, because it gives a false sense of security. Contact our team for a tailored quote based on your specific requirements.