Key facts on the implementation of Regulation (EC) 2073/2005 for meat and meat products
The HACCP concept as the key to successful pathogen management
March 2021. Recently, several decisions have been made in the meat industry on the implementation of the European regulation on microbiological criteria for foodstuffs, which highlight the obligations and consequences in the case of pre-products and end products for entrepreneurs of all food categories. Therefore, we outline here the background situation and show which recommendations you can derive from it for your own food safety management.
Legislation on Salmonella and Listeria in meat products according to Regulation (EC) No. 2073/2005
According to Regulation (EC) No. 2073/2005, Salmonella limits are part of the food safety criteria. Salmonella must not be detectable in meat products made from poultry meat, minced meat and other types of meat intended for consumption in a heated-through state (negative in 25 g poultry meat or 10 g other types of meat). The manufacturer must sample its products in the ready-to-serve state to ensure food safety. If the microbiological examination of the product shows contamination with Salmonella, the product must be withdrawn from the market and the competent authority must be informed about the initiated withdrawal.
In the case of Listeria, for food products that support the growth of Listeria monocytogenes, the detection must be negative in 25 g before the (pre-)product leaves the direct control of the food business operator. For ready-to-eat products, a limit of 100 cfu/g must not be exceeded until the end of shelf life. In addition, the sampling plan must provide a sampling of processing areas and equipment.
Listeria and challenge tests in the focus of the authorities
Regulation (EC) No. 2073/2005 stipulates that a value of 100 cfu/g must not be exceeded in ready-to-eat foods that promote the growth of Listeria monocytogenes until the end of shelf life. Consequently, it is necessary to determine the multiplication potential of Listeria in the respective foodstuff. Challenge tests, which can be used to quantify the growth potential of Listeria in or on foodstuffs, are of particular importance in the context of in-house control systems.
How to proceed in the sense of Regulation (EC) No. 2073/2005 is determined in the food control authorities with the help of so-called decision trees. In Baden-Württemberg, the decision tree was recently revised with regard to listeria and challenge tests. This is now to be coordinated between the individual federal states.
In the case of very perishable foodstuffs, which may pose a risk to human health after a short period of time, the best-before date is replaced by the use-by date. Classic examples are minced meat or poultry products. However, ready-to-eat foods that favour the multiplication of listeria (e.g. cold cuts) may also pose an immediate risk to human health after a shelf life of several weeks has expired. Foods for which the risk of contamination with Listeria cannot be ruled out must therefore be considered unsafe after the expiry of the shelf life.
Safety from the primary stage to the end product:
Salmonella as a food safety criterion using the example of kebab
The handling of listeria described at the beginning of this article makes it clear that the responsibility of the food company along the entire process chain includes microbiological criteria in accordance with Regulation (EC) 2073/2005. This is also confirmed by a recent court decision concerning salmonella.
A food producer manufactured raw meat skewers, froze them and sold them to restaurants with the note "Cook completely before consumption." Then the meat skewers were heated and sold as kebabs to end consumers. According to the hygiene concept of the food business operator, random checks were carried out before delivery. The company's HACCP concept did not provide for a recall in the event of a positive salmonella finding, since the result (due to the heating) was a safe food product.
However, the responsible food monitoring authority criticized this. From the authority’s point of view, the result could only be obtained once the product had reached the customer and was consequently already on the market. The positive salmonella result was therefore a criterion that affected the acceptability of the food.
The German Federal Administrative Court ruled in favour of the food authority. According to the ruling (14.10.2020 – File no. 3 C 10.19), it was irrelevant whether a health risk to the end consumer could be avoided by proper cooking in the catering establishments or whether the food had already been placed on the market. The microbiological criteria must comply with the requirements of the European Regulation (EC) No. 2073/2005. Thus, the salmonella finding was evaluated as a food safety criterion and the food business operator was requested to adapt the hygiene concept.
Consequences for your operational HACCP concept
The examples outlined here make it clear that all food business operators at all stages of production are obliged to carry out tests in accordance with Regulation (EC) No. 2073/2005. In the case of microbiological exceedances as well as unsatisfactory results with regard to food safety criteria, a withdrawal of the batch concerned must take place in accordance with the regulation.
The regulation aims at a high level of protection of public health. In order to avoid a product recall, we therefore recommend that food business operators carry out the required tests prior to distribution to the trade or to consumers. This requires a hygiene concept based on the HACCP principles to ensure compliance with the safety criteria at all stages of production, processing and distribution.
Managing food safety together - with analyses from Eurofins
We are happy to support and advise you in the preparation of your HACCP hygiene concept, carry out challenge tests and offer you the appropriate microbiological analyses to ensure the marketability of your products. Contact your personal account manager or our expert Dr Anna Fecke.
