Regulatory change regarding Listeria monocytogenes criteria in ready-to-eat foods

We wish to inform you of an important change in the regulations concerning ready-to-eat foodstuffs (category 1.2 of Regulation (EC) No. 2073/2005). The new regulation (EU) 2024/2895, which came into force on December 11, 2024, will apply from July 1, 2026.

What's new :

- Previous regulations: Regulation (EC) no. 2073/2005 (1)

For products where Listeria monocytogenes can grow, the manufacturer must now demonstrate, to the satisfaction of the competent authority, that the 100 CFU/g limit is respected until the end of the shelf-life. If this proof is not provided, the product must meet the strict criterion of not detected in 25 g.

Products concerned :

Ready-to-eat (RTE) foods that support the growth of Listeria monocytogenes, (with the exception of products for infants and foods for special medical purposes). Either :
- Smoked fish
- Cold cuts
- Certain unpasteurized dairy products / raw milk cheeses
- Certain prepared salads (containing seafood, for example)

Food industry operators have until July 1, 2026 to comply with the new requirements.
Various tools are available to validate and/or verify the shelf life of a RTE product. They are listed in the regulations and in particular in the DGAL's technical instruction (DGAL/SDSSA/2024-270):
- Challenge tests: Experimental contamination to monitor the evolution of Listeria monocytogenes.
- Predictive microbiology: mathematical models to predict bacterial behavior.

References:
1) Regulation (EC) No. 2073/2005 – initial European text defining microbiological criteria applicable to foodstuffs, including MAP.
2) Regulation (EU) 2024/2895 – recent update strengthening the requirements for the control of Listeria monocytogenes and specifying the application throughout the shelf life of products.
3) Instruction DGAL/SDSSA/2023-27 – specifies the categorization of MAP/non-MAP products and the physicochemical criteria used to determine growth potential.
4) Instruction DGAL/SDSSA/2024-270 – details the methods and tools (challenge tests, predictive microbiology) for demonstrating compliance with the new criteria and adapting control plans.

Our microbiology laboratory in Avignon can provide these services. The CTCPA is a member of the Sym'Previus scientific interest group (GIS).

For more information, please contact us at: microbiologie.contact@ctcpa.org