In September 2026 we wrote twice to the Lithuanian State Food and Veterinary Service (VMVT) asking when a chef cooking in a client's home has to register as a food business operator. Both questions and both replies are below, translated from Lithuanian.
This is a translation.
The replies were issued in Lithuanian. Each quotation below is given first in English and then in the original wording. Where the translation and the original differ, the Lithuanian text prevails.
The chef cooks with the client's groceries
No VMVT registration needed
Lawful economic activity and a health check are enough.
The chef uses groceries they bought themselves
VMVT registration is mandatory
Even where the groceries were bought on the client's instruction and reimbursed exactly against the receipt.
A natural person plans to travel regularly and for payment to different people's homes and cook for them in their kitchen — each time in a different kitchen, never their own. Is registering an individual activity enough, or does this work also require registration with VMVT as a food business operator?
VMVT began by noting that the economic activity has to be lawful — for example, a business certificate issued under order No. 333 of the Head of the State Tax Inspectorate of 21 November 2002. Then comes the substance:
“If in the course of your activity you provided only a preparation service using the clients' food, that would not be regarded as food handling and such activity would not have to be registered with VMVT in the established manner.”
“If in the course of such activity you used food acquired by you, then such food handling activity would have to be notified to VMVT under the Requirements for the approval and registration of food business operators <…>”
VMVT reply of 15 September 2026, ref. ASK-5789-(7.73 E)Original„Jeigu veiklos metu Jūs teiktumėte tik gamybos paslaugą iš klientų maisto, tuomet tai nebūtų laikoma maisto tvarkymu ir nereiktų registruoti tokios veiklos VMVT nustatyta tvarka.“ · „Jeigu tokios veiklos metu naudotumėte Jūsų įsigytą maistą, tuomet apie tokią maisto tvarkymo veiklą turėtų būti pranešta VMVT pagal Maisto tvarkymo subjektų patvirtinimo ir registravimo reikalavimus <…>“
As possible activity codes the reply lists “56.21 Event catering / catering under contract”, “10.85.0.GMK Production of prepared meals and dishes in small quantities”, “56.29.K Other food service activities”, or whichever code best matches the planned work.
The client draws up the shopping list themselves and instructs the chef to buy the groceries in the client's name, at the client's expense and in the client's interest. The chef buys them on the way and delivers them straight to the client the same day without delay — the groceries are not stored, warehoused or repackaged anywhere. The till receipt is handed to the client, who immediately reimburses the cost exactly as per the receipt, with no markup. The food is cooked only in the client's kitchen and stays in their home. Does such activity fall within the exception stated earlier?
“In this case you would be responsible for the food acquired and for its handling (storage, transport, preparation) at the venue. You would be performing actions characteristic of a food business operator, that is, you would be taking part in the food supply chain. The activity would have to be registered with VMVT in the established manner.”
VMVT reply of 23 September 2026, ref. ASK-6048-(7.73 E), annexOriginal„Šiuo atveju, Jūs būtumėte atsakingas už įsigyjamą maistą, tvarkymą (laikymą, transportavimą, paruošimą) renginio vietoje. Atliktumėte veiksmus būdingus maisto tvarkymo subjektui, t. y. dalyvautumėte maisto tiekimo grandinėje. Veikla turėtų būti registruojama VMVT nustatyta tvarka.“
Asked what conditions would have to be met for the activity not to count as food handling, the reply is brief:
“None of the factual circumstances described in cases 1–4 may be present.”
Same replyOriginal„Neturi būti faktinių aplinkybių, nurodytų apibūdinant veiklą 1–4 atvejuose.“
In other words, none of the described circumstances changes the assessment — neither the receipt being in the client's name, nor the groceries never being stored, nor reimbursement without a markup.
The same reply states that people handling food are subject to clauses 12 and 13 of HN 15:2021, chapters VIII and XII of Annex II to Regulation (EC) No 852/2004, and Resolution No. 544 of the Government of the Republic of Lithuania of 7 May 1999. Under that resolution, health is checked for tuberculosis before starting work and annually thereafter, with the conclusion entered in the personal medical record (form No. 048/a). The reply notes separately that, under item 4 of the List, service providers are also health-checked where services are provided at the recipient's home. Mandatory hygiene skills training is carried out under order No. V-69 of the Minister of Health.
Download the full reply, PDF (Lithuanian)These are written consultations, not legislation.
They were given on the specific circumstances described in our enquiries and do not replace a consultation of your own with VMVT. Legislation changes — check the versions in force. You can put your own question to klausimai@vmvt.lt or call 1879.