There has been no change to the hygiene training requirements for food handlers. The EU Regulations have in fact been in force now for 8 years. They state that, “Food business operators are to ensure that food handlers are supervised and instructed and/or trained in food hygiene matters commensurate with their work activity.” (Regulation (EC) 852/2004, Annex11, Chapter XII, paragraph 1.)
This wording is very little different to the old UK General Food Hygiene Regulations of the early 1990's which in turn mirrored previous legislation.
Even under the Butchers Licensing regime there were no specific training requirements and the official FSA guidance at the time stated, “While success in an examination following a training course is desirable, it is not a condition of the licensing regulations. It would therefore be inappropriate for enforcement officers to assess compliance solely on the basis of a pass result or certificate obtained by the candidate.”
EHO's will often recommend training or refresher training but in strict legal terms they cannot insist. However if they consider that your staff are not carrying out their duties properly and hygienically they have other powers to make life very difficult for you. In practical terms therefore it is often better that all staff do a level 2 food hygiene certificate.