Feedback shows that there is no support for planned changes to the EU Listeria

More than 80 comments have been submitted on plans to update Listeria monocytogenes rules on ready-to-eat foods in Europe.

Many submissions opposed the proposals, raising concerns about how they would work in practice, as well as issues around challenge testing and the fact that a zero-tolerance approach deters companies from testing and leads to issues not being discovered.

The majority of respondents consisted of companies or business associations. More than a quarter came from Britain, while 13 came from France and 12 from Spain.

The new rules would apply to RTE foods, with the exception of foods intended for infants and for special medical purposes that may support the growth of Listeria monocytogenes. The regulation will not apply until January 2026 at the earliest.

The Chilled Food Association said current legislation is effective if it is enforced and does not need to be changed. The group added that legislation and guidelines are not being enforced effectively or in a risk-oriented manner in the countries where interest rates have escalated.

Lack of support for changes
Comments from groups including the Food and Drink Federation, Dairy UK and Provision Trade Federation supported the position of the Industry Listeria Group, which said the proposed changes are a move away from the current risk-based approach to a hazard-based law.

“It is likely that extending the amount of undetected Listeria monocytogenes in 25 grams and having to prove that the product will not exceed the limit of 100 cfu/g during the remaining shelf life will lead to problems when products are produced in one Member State . state and is distributed in another.”

Respondents were also concerned that applying zero tolerance during shelf life could result in products testing negative as they leave food industry control, while testing positive later in the chain without a clear view of the history of the products sampled, such as temperature abuse in the distribution chain.

The Czech Agriculture and Food Inspection Authority (SZPI) said the amendment imposes more obligations and financial burdens both on control authorities and on the food industry.

Pilgrims Europe said it was “deeply concerned” by the proposals.

“The control of Listeria monocytogenes in food production is achieved through good hygiene practices, adequate environmental monitoring, historical trends, HACCP and adherence to an appropriate shelf life,” said the company, which produces ready-to-eat chicken and pork, among other products. ready-made meals, meat-free products and snacks.

“We do not believe the proposals will improve food safety and will not achieve the aim of reversing the rising number of listeriosis cases in some Member States. In relation to our business footprint, particularly our unique situation with businesses in the EU, Northern Ireland and Great Britain, we would also have concerns about enforcement in these three different locations.”

Challenge test problems
Convenience food supplier Greencore said the plans could lead to a reduction in environmental monitoring and increased industry reliance on challenge tests as a check.

“A move towards this approach could give food companies a false sense of security, when ongoing controls should be key. Testing does not make a product safe and is only a sample and should never replace good hygiene practices, HACCP and best practice shelf life principles.”

A joint submission from the European Sprouted Seeds Association and Freshfel Europe – European Fresh Produce Association states that while the complete absence of Listeria monocytogenes should always be the goal, for certain foods, such as raw fruit and vegetables, this is not achievable.

“Any efforts made in end product control, including challenge testing, divert financial resources from cleaning and disinfection and environmental health monitoring, which are critical requirements for HACCP. The challenge test cannot replicate factory conditions, nor can it replace the amount of experimental data and professional knowledge.

“Failure to detect Listeria monocytogenes in a 25-gram sample does not guarantee its absence in an entire batch, and if Listeria monocytogenes is detected in a 25-gram sample it does not mean that the entire batch is contaminated.”

The consequences of applying a zero tolerance limit are that the number of tests on finished products will decrease, as is the case in the United States, due to the fear of encountering Listeria monocytogenes and experiencing product recalls, with the associated damage to brand reputation and costs to the industry, the European Dairy Association said.

EuroCommerce, which represents the retail and wholesale sectors, said this move could lead to unnecessary product recalls, which could lead to food waste, even when Listeria is detected at low levels that do not pose a food safety risk at the end of the product’s shelf life. product. .

(To sign up for a free subscription to Food Safety News, click here.)