More than 80 comments have been submitted on the planned update of the Listeria monocytogenes regulation for ready-to-eat food (RTE) in Europe.
A number of proposals opposed the proposal, raising concerns about how the proposal would work in practice, issues with challenge testing, and the fact that a zero-tolerance approach would keep companies away from testing and problems would go undetected.
The majority of respondents were companies or business associations. More than a quarter were from the UK, 13 from France and 12 from Spain.
The new rules apply to RTE foods, except those intended for infants and for special medical purposes that can support the growth of Listeria monocytogenes. The earliest this regulation will apply is January 2026.
The Chilled Foods Association said the current law was in effect when it came into force and there was no need to change it. The group added that in countries where interest rates are rising, laws and guidance are not being effectively enforced and enforcement is not focused on risk.
Lack of support for change
Comments from bodies such as the Food and Drink Federation, the British Dairy Federation and the Food Trade Federation support the Industry Listeria Group's position that the proposed changes are a move from the current risk-based approach to hazard-based legislation. did.
“Products produced in one member must extend the period during which L. monocytogenes is undetectable at 25 grams and demonstrate that the product does not exceed the 100 cfu/g limit throughout its remaining shelf life. This may cause problems if the state is distributed between states.
Respondents also found that zero tolerance during the best before date would result in a negative product test once it leaves the control of the food business, while at a later stage the history of the sampled product (temperature abuse in the food industry) They were concerned that there was a possibility that the test results would be positive without a clear understanding of the symptoms (e.g.). distribution chain.
The Czech Agricultural and Food Inspection Service (SZPI) said the amendments would create additional obligations and financial burdens for both the regulatory authorities and the food industry.
Pilgrims Europe said it was “deeply concerned” about the proposal.
“Control of Listeria monocytogenes in food manufacturing is accomplished by observing good hygiene practices, proper environmental monitoring, historical trends, HACCP, and appropriate shelf life,” says Ready-to-Eat Poultry and Pork. said the company, whose products include Prepared meals, meatless products, and snacks.
“We do not believe that this proposal will improve food safety, nor will it achieve the goal of reversing the rate of increase in listeriosis in some Member States. Our footprint, We will also have concerns about enforcement across these three different locations, particularly given our unique situation with operations in the EU, Northern Ireland and the United Kingdom.”
Challenge test concerns
Ready-to-eat food provider Greencore said the plan could reduce environmental monitoring and increase the industry's reliance on stress testing as a control.
“Despite the need to focus on continuous and continuous control, moving to this approach can give food companies a false sense of security. Testing does not make a product safe. , is merely a sampling exercise and does not replace good hygiene practices, HACCP, and best practice shelf life principles.
A joint submission from the European Sprouted Seed Association and Freshfell Europe – European Fresh Produce Association states that while complete elimination of L. monocytogenes should always be the goal, certain foods, such as fresh fruits and vegetables, states that it is not possible.
“Every effort is spent on controlling the final product, including challenge testing, and financial resources are wasted on cleaning and disinfection, which are key prerequisites for HACCP, and monitoring environmental health. Challenge testing involves replicating factory conditions. cannot replace large amounts of experimental data and expertise.
“The absence of L. monocytogenes in a 25 gram sample does not guarantee that L. monocytogenes will not be detected in the entire batch; L. monocytogenes was detected in a 25 gram sample.” However, this does not mean that the entire batch is contaminated.
The consequence of zero tolerance, as seen in the US, is that fear of Listeria discoveries and product recalls will lead to less testing of finished products, resulting in reduced brand reputation and costs to the industry. will be reduced, he said. European Dairy Association.
Eurocommerce, which represents the retail and wholesale industry, said the measure could lead to unnecessary product recalls and that Listeria monocytogenes is detected at low levels that do not threaten food safety at the end of a product's shelf life. But he said it could lead to food waste. .
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