Direct Sales Regulations for Agricultural Producers in Poland: The RHD Framework
Market stall selling produce directly to consumers. Photo: Wikimedia Commons, CC.
Since 2017, Polish agricultural producers have had access to a distinct legal pathway for selling food directly to end consumers and the hospitality sector. Known as Rolniczy Handel Detaliczny (RHD — Farm Retail Trade), this framework was introduced by an amendment to the Act on Food Safety and Nutrition and removes several of the approval barriers that previously applied to small-scale on-farm processing and direct sales.
Who Qualifies for RHD Status
RHD registration is available to natural persons who are registered farmers in Poland and who produce the goods they intend to sell from their own agricultural holdings. The core requirement is that the primary raw material must originate from the seller's own farm. The regulations permit limited use of externally sourced ingredients as secondary inputs, subject to defined proportions depending on the product category.
Legal entities (companies) do not qualify for the RHD framework. The scheme is designed specifically for individual agricultural producers and farmer families. Cooperative arrangements exist outside RHD under different legal provisions.
RHD registration is handled through the local powiat veterinary inspectorate (for animal-derived products) or the local Sanepid office (for plant-derived products). Registration is free of charge and does not require prior approval — producers notify the relevant authority before beginning sales.
Annual Turnover Thresholds
The RHD framework includes an annual revenue ceiling. As of the last published update by the Ministry of Agriculture, the threshold for tax-exempt RHD income is tied to a multiple of the average declared monthly income for farmers (as used in KRUS calculations). The applicable limit is reviewed periodically and published at minrol.gov.pl.
When a producer's RHD revenue exceeds the applicable threshold in a given calendar year, the surplus becomes subject to standard income tax reporting under the PIT framework. The obligation to track and report this applies from the first PLN above the threshold, not retrospectively to the full year's income.
Permitted Product Categories
The range of products that can be sold under RHD covers both raw agricultural commodities and processed food made predominantly from own-farm produce. The main categories include:
- Fresh fruit and vegetables (unprocessed)
- Cereal grains and flour milled on the farm
- Eggs (subject to hygiene and labelling rules for small flock producers)
- Raw honey and beekeeping products
- Fresh milk and unaged dairy products prepared from own-herd milk
- Meat from animals slaughtered at approved facilities, where the producer holds the necessary veterinary clearance
- Cured, smoked, and otherwise processed meat products where own-farm meat constitutes the primary ingredient
- Preserved fruit and vegetables (jams, pickles, dried products) where the base material is own-farm produce
- Bread and baked goods where the primary grain component comes from own-farm cultivation
Products containing more than 50% externally sourced ingredients by weight are generally excluded from RHD, though the exact ratios differ by product type. Current guidance is published by the Ministry of Agriculture.
Where RHD Sales Are Permitted
Polish law allows RHD sales in the following contexts:
| Sales Channel | Conditions |
|---|---|
| Farm gate (on-farm sales) | No geographic restriction; available at the producer's own holding |
| Farmers markets and bazaars | Permitted at licensed market sites; producer must be present or represented by a household member |
| Mobile sales (vehicle-based) | Permitted with appropriate municipal notification; subject to local bylaws |
| Direct to food businesses (hospitality) | Permitted for most product categories; the receiving business must not resell the product as a commodity |
| Online with direct delivery | Permitted when the producer handles fulfilment directly; reselling through general e-commerce platforms is subject to additional review |
Record-Keeping Requirements
RHD producers are required to maintain sales records documenting the quantity and type of products sold, the date of each transaction, and the identity of the buyer when selling to food businesses. For consumer sales at markets, individual transaction records are not required, but aggregate monthly records are.
These records must be retained for a minimum of five years and must be made available to the relevant inspectorate (veterinary or sanitary) upon request. Producers who miss the notification deadline before beginning RHD activity or who fail to maintain records may lose the exemption from standard food business licensing.
Hygiene and Labelling Requirements
RHD does not exempt producers from EU food hygiene requirements. The relevant EU regulations — Regulation (EC) 852/2004 and Regulation (EC) 853/2004 — apply with certain flexibilities for small-scale and direct producers as transposed into Polish law. In practice this means:
- Food contact surfaces must be kept clean and in good condition
- Temperature controls apply to perishable items during transport and display
- Labelling must include the producer's name and address, the product description, and a list of ingredients where applicable
- For pre-packaged goods: net weight, production date or best-before date, and allergen declarations
Changes and Updates to the RHD Regime
The RHD framework has been amended several times since its 2017 introduction, primarily to expand the list of permitted product categories and adjust turnover thresholds. Producers who registered under earlier versions of the rules are advised to check current guidance from the Ministry of Agriculture, as some conditions have changed since initial registration. The most current consolidated text of the relevant regulations is available through the ISAP legal information system (Internetowy System Aktów Prawnych).