To open a brewery in Russia, you need to collect a lot of documents, to get permissions, to agree on the beginning of work with the Federal Service for Regulation of the Alcohol Market, to connect the EGAIS (Integrated State Automated Information System), to develop HACCP (Hazard Analysis and Critical Control Point) documents... For a person, who isn’t familiar with all this, opening a brewery seems to be extremely complicated.
Sergey Kostomarov, the owner of the Pinewood brewery, has developed a guideline based on his own experience - a step by step manual beginning with the getting a permission for the brewing, cider, perry and mead production and to the HACCP documents. The guideline contains more than 100 pages; the Profibeer is publishing an extract about the preparatory stage of the setting up a brewery.
I developed this guideline to help those, who do not know, where to start setting up the brewery and what documents are required for this.
Often, we appeal to our local authorities asking for help, but do not receive all the necessary information. After that, we look for information on the Internet, we interview friends, spend a lot of time and money. My colleagues and I had started exactly the same, so we spent a very long time on all this.
The preparation has several stages:
• The room
• Equipment installation and inspection of the documents
• Test samples production, analysis and getting a declaration
• Calculation of production capacity, notification about the start of production
• Connection to the EGAIS
• Developing of HACCP documents
According to the Federal Law №171-FZ of 22.11. 1995, the production of alcoholic beverages may be carried out by the organization, which have production and storage facilities in their property, economic management, operational management or lease which is determined by the contract and should be one year or more.
The facilities should correspond to the requirements established by the authorized Government of the Russian Federation, a federal executive authority.
Reference. I’d like to point out, that to start the production you must register an LLC .Concerning the lease we have the following experience: we made an agreement with the landlord for 11 months, and the Federal Service for Regulation of the Alcohol Market did not have any objections!
Today brewing is regulated by the Sanitary rules for enterprises of the brewing industry and the industry of the nonalcoholic beverages of 09.04.1985, which contain a number of basic requirements:
• the room must be lit;
• containers and households supplies should be stored in the storage area;
• grains should be collected into the waterproof boxes;
• garbage should collected into a waterproof container located min. 25 m away from production and storage facilities;
•the water should meet the for drinking water requirements. If there is a well, then installation of filters is required. On the territory of the Russian Federation, the city's water supply automatically falls under the category "drinking water";
• hot water should comply with the State Standards (GOST);
• the production unit should be equipped with a washbasin with hot water, soap and hand-drier;
• ventilation system;
• availability of municipal canaliyation or septic tank;
• do not place the production unit in the basement or semi-basement, except the fermenting cellar;
• the entrance to the production unit must be provided with disinfectant bath;
• walls should be covered with tiles or painted with washable tiles to a height of not less than 1.75 meters. Today it’s allowed to use metal profile, plastic panels;
• the floor must be without cracks, chips, pits. If you have a tiled floor, it's good. If it is a concrete floor, then we recommend using epoxy floor;
• storage of raw materials in the boiling room is prohibited.
For more details see on the Internet the Sanitary rules for enterprises of the brewing industry and the industry of the nonalcoholic beverages of 09.04.1985.
The Decree of the Federal Service for the Alcohol Market Regulation №59 from 26.10.2010 regulates the storage of the final products.
Beer must be stored in a lit room with temperature from 0 to 25 degrees Celsius and equipped with trays or racks.
There are no requirements established concerning the min. square area of the production space.
Production should be no closer than 50 meters from residential buildings, but the reduction in this distance can be agreed with Rospotrebnadzor. If the enterprise is recognized as harmless, you can set up a brewery with at almost any distance from the houses.
There is no need to call for a check nor the Health Inspection Service (SES), nor Rostekhnadzor, nor MChS (Ministry for Civil Defence, Emergency Management and Natural Disaster Response). They will come to you 3 years after the moment of registration. It’s not necessary to inform Rospotrebnadzor about the commencement of your activities: breweries are not included in the list of organizations that should notify them.
To get the brewing permission, you must have documents for the following equipment:
• the brewery complex passport;
• a declaration or certificate of conformity for the main process equipment, namely:
• brewing line
• tanks for fermentation and second fermentation
• capping / pouring / combined machine (if available)
• equipment for water correction or softening (if available)
If your equipment is not certified or not declared, or if there is no brewing complex passport, you should do it /get it in any case. You will need a brewing complex passport; you can develop it by yourself.
It will be also necessary to put identifying information on the brewing line and fermentation tanks. You can put all the necessary information on the equipment by engraving it or fixing the sign plates.
Reference. If you use intake head to pour the beer into the keg, you should know, that no declaration or certificate is provided for this device. If you pour beer into the glass manually, the Federal Service for the Alcohol Market Regulation can request a certificate / declaration for the dispensing device and, in case of its absence, may refuse to authorize the production. The reasons are unknown, since in the list of basic technological equipment approved by Federal Service for the Alcohol Market Regulation are allowed only automatic devices.
If you have all the documents on hand, you can proceed to the next procedure.
To get all the documents necessary for your products, you should declare it. For this you should contact the certification authority. There are two ways – the official one and the "gray" one.
This is the easiest and the fastest way. You will get the declaration within 1-2 days, it is legal, but laboratory tests will not be assigned to it (in the future, laboratory tests will be applied on the certificate verification server for the authenticity of the certificate). You need only a technological instruction. There are a lot of such centers, they can be quickly found on the Internet. This option is also cheaper and will cost about 4000 Rubles.
It will cost you about a week. You will need a technological instruction for your beer, an industrial control program, and laboratory tests.
You apply to the Center for Standardization and Metrology (ZSM), where you will be asked to show the technological instructions and the production control program, you will also need to indicate according to which standards you will produce beer. If you are going to produce beer according to the technological instructios, it can be developed in ZSM, further you can go to the service station or to mark the standard (GOST).
Further, your beer will be given for laboratory tests or write out the direction. Beer must be should be in the tare, in which you plan to sell it. After receiving the documents about the laboratory tests you will get the declaration from the Center for Standardization and Metrology.
The whole procedure will cost about 15,000 Rubles.
In technological instruction you can specify all the varieties that you want to produce, but with description of all the features, or make the separate one for each beer variety.
Reference: For the registration we have chosen the standard GOST 31711-2012. The beer was submitted in a glass container. By the Center for Standardization and Metrology we’ve also received a free certificate of conformity for beer, which should ensure the reliability of the brewery and our attention to the product. If you are afraid for some reason not to undergo the laboratory tests, you may buy a beer at a nearby store, stick your label on it and, believe me, you will pass the procedure.
So, you have all the documents for the equipment and products. Now it is necessary to develop executive orders for your company, which will help you to calculate correctly the production capacity. You may send the calculation both by post and by e-mail: info@fsrar.ru.
You also need to purchase an EDS [note: electronic digital signature] for reporting to the Federal Service for Regulation of the Alcohol Market. With the help of EDS, you must register on the following web-sites: https://service.fsrar.ru and https://frap.fsrar.ru.
On a site https://frap.fsrar.ru it is necessary to register the product, which you plan to deliver. Each beer variation should be registered on the site separately! If you are going to brew a new beer, then again it will have to be registered on the website. For more details see Appendix 15 of the guideline.
The products should be accompanied with downloaded label. In case of any error a message about necessary corrections will display on the site. There are no difficulties in filling the necessary data, everything is simple.
After sending the calculation to the Federal Service for Regulation of the Alcohol Market, prepare all the necessary documents. Now you should wait for the inspection from the Federal Service for Regulation of the Alcohol Market. Usually, they notify you about the arrival by phone a couple of days before the check.
Reference. You should prepare a declaration / certificates for beer. The Federal Service for Regulation of the Alcohol Market may request it. The vats should be empty! They will photograph the production and equipment; ask how the whole technological process goes. If there is something in the vats, you will have to write an explanatory report. Write that you were trying to make some kvass or were checking the equipment, making some samples.
After all, you will have to sign the inspection report, and after that - permission for the production of beer, cider, mead, poire.
To connect to EGAIS, you must purchase a digital JaCarta key of the TsentrInform. It costs about 3000 Rubles. You can order it on their website or in the partner offices in your city.
To work with JaCarta you will need to install the special software. Together with the key you’ll get a detailed instruction for work with JaCarta.
To send consignment notes in EGAIS you can download for free the program "Wholesale customer" from the website of TsentrInform. If the program cannot be downloaded, you can contact me, I have the source code.
Now you have everything you need to start working officially!
The following documents are required:
1. HACCP
Regulations on the food safety
http://www.fao.org/3/a-i0096r.pdf
2. Incoming inspection (Appendix 3)
• Incoming inspection procedure.
• Logs of the incoming inspection of the main and auxiliary raw materials and equipment.
• Documentation verifying the quality and safety of raw materials, equipment, materials, including lubricants (veterinary certificates, declarations of conformity, quality certificates, etc.).
3. Production control program (Appendix 3)
• Production Control Program approved by the management and / or the sanitary and epidemiological surveillance.
• Inspection plan of sanitary and hygienic state of production.
• Microbiological control plan.
• Physical and chemical control plan.
• Control program of maximum admissible emissions into the environment.
• Laboratory tests protocols, confirming the adherence to plans and programs.
4. Technological processes (Appendix 2)
• Processing instructions for the production of each product group.
• Operating instructions for each workplace.
5. Medical examination for personnel
• Employee illness log.
•Llog of work permit of the employees.
• Medical records of the employees with marks on the passed medical examination, fluorography examination and hygiene education courses.
• Contract for the medical examination of workers.
• Medical examinations plan.
6. Reception of visitors
• The procedure for reception of visitors in the production facilities.
7. Compliance with personal hygiene rules (Appendix 17)
• Personal and professional hygiene rules.
8. Washing and disinfection (Appendices 18, 21, 22, 23, 24)
• Plan for cleaning and disinfection of production facilities with an indication of the frequency of processing in industrial buildings (including fixtures, glazed skylights, and areas of possible accumulation of dirt).
• Instruction for the sanitary processing of facilities, equipment and inventory.
• Sanitation and facilities general cleaning plan.
• The list of used detergents and disinfectants (instructions for use, documentation of their quality and safety).
• Journal of detergents and disinfectants detergents, disinfection quality control, instructions on preparing of working solution.
• Control log of the used percentage concentrations of detergents and disinfectants.
•Operation log of the specialized disinfection equipment (sterilizers, germicidal lamp, etc.).
• The contract for disinfection works.
9. Air conditioning, ventilation, heating
• Contract for maintenance of the ventilation system.
• Ventilation plan of the enterprise.
• Control logs of temperature and humidity conditions at the production and storage facilities, cold storage rooms.
10. Water supply and canalization
• The agreement with the State supervision bodies for water control.
• A protocol of laboratory water control.
• Water supply and canalization plan of the enterprise.
11. Equipment maintenance
• A passport for each piece of equipment.
• Plan of preventive equipment maintenance.
• Records confirming the planned equipment maintenance.
• Contract for maintenance of the technically difficult equipment.
12. Production, storage and auxiliary rooms
• The premises plan with names of buildings and constructions.
• Facilities plan with equipment.
13. Metrological support
• Passport for each unit of the control and measuring equipment (scales, thermometers, etc).
• Contract for the metrological control.
• Calibration plan of test equipment.
• Test equipment calibration certificate.
14. Professional training and awareness
• Job descriptions.
• Employee training program (schedule, log).
15. Deratization and disinsection (Appendix 19)
• Contract for disinfestation and disinfestation works.
• Documentation confirming the planned deratization and disinsection works (log, etc.).
• Plan of rodent traps.
• Documentation confirming of the quality of the baits for rodents and insects.
16. Motor transport
• Contract for the sanitary treatment of vehicles.
• Log of temperature monitoring during the transportation (of raw materials, products).
• Log of cleaning and disinfection of the vehicles.
17. Waste management
• The contract for waste removal from the territory of the enterprise.
• Plan of garbage collection.
• The contract for the production waste disposal.
18. Finished goods quality assurance
• Quality control of finished goods.
• Normative and technical documentation used for manufacturing the product (federal standards, technical instructions, technical specifications).
• Sanitary-Epidemiological conclusion certificate on the manufactured products.
•List of quality certificate.
19. Laboratory tests
• Laboratory protocols of the following tests: water, the main and auxiliary raw materials, finished products, swabs from the equipment, tools, hands, protective clothing; air control.
• Good Laboratory Practice procedures (test log, etc.).
• Sample collection for various tests and manipulations, sample collections acts.
20. Management of nonconforming products
• Withdraw of products from the market in case of its nonconformance, instructions for the further manipulations with the nonconforming products.
• Quick reaction in case of critical situation (wrong protocols of laboratory tests, etc.).
• Quick reaction in case of emergency (breakdown of equipment, sewage breakout, etc..).
21. Management of hazardous factors
• Instructions on working with glass and plastic objects, if such are used in production.
• Instructions on working with wooden objects, if such are used in production.
All the appendices listed are available only in the guideline.
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