Commission Regulation (EU) 2024/2895 replaced entry 1.2 in Annex I of Regulation 2073/2005, the microbiological criteria regulation. The entry covers ready-to-eat foods that support Listeria growth, other than those for infants and for special medical purposes.
| Situation | Old text | From 1 July 2026 |
|---|---|---|
| Producer has shown 100 cfu/g will not be exceeded during shelf life | 100 cfu/g while on the market during shelf life | Unchanged |
| Producer has not shown it | Not detected in 25 g, only until the product left the producer's control | Not detected in 25 g, at every stage while the product is on the market during shelf life |
That was the gap in the old text: once a product left the producer, no not-detected criterion applied for the rest of its shelf life. Listeria can grow at refrigerator temperature, so the shelf-life evidence depends on the temperature the product spends that time at. Two degrees in the warehouse and eight in the vehicle do not give the same shelf life.
According to the Commission guidance, shelf-life studies are run under reasonably foreseeable conditions of distribution, storage and use. Three measurements make up the shipping part of those conditions: the real temperature range on the road, the number and length of door openings, and the wait between delivery and reaching the shelf. Pulling them from batch-linked records is logistics' job; updating the study is quality's.
Keep the records of normal days as well as deviation days, because it is the record without deviations that supports the shelf-life claim. Where the records do not match the study's assumption, the study is redone with field conditions.
