New EU rules on Listeria: what will change from 1 July 2026?
As of 1 July 2026, stricter rules apply for Listeria monocytogenes in ready-to-eat foods. The change comes from Regulation (EU) 2024/2895, which amends the existing Regulation (EC) 2073/2005. For producers and processors of ready-to-eat products, this means you must be better able to demonstrate that your product remains safe, from production until the end of its shelf life.
What changes exactly?
The amendment specifically targets ready-to-eat products that can support the growth of Listeria monocytogenes (think smoked fish, raw milk cheeses, pre-packaged deli meats, coleslaw salads or chilled ready-to-eat meals). For these products, two possible criteria apply from 1 July 2026:
- Can you scientifically demonstrate that the bacterium does not grow above 100 cfu/g throughout the entire shelf life? Then the more lenient criterion of max. 100 cfu/g continues to apply. (subject to exceptions)
- Can you not demonstrate this? Then Listeria monocytogenes must be absent in 25 grams of product, and this throughout the entire shelf life. In other words, no longer only until the product leaves the factory, as is currently still the case. (except in the legally provided exceptional cases)
This last change is the crux of the matter: the producer’s responsibility no longer ends at the factory gate, but extends throughout storage, transport and further processing in the chain.
Does everything need to be ready by 1 July 2026?
This is the most concrete question for many businesses, and the answer requires some nuance. The regulation does not require that every individual product has already completed a fully finished challenge test or predictive study by 1 July 2026. What it does require is a scientifically substantiated approach: a clear classification of your products, a justification of why a product does or does not support Listeria growth, and (where necessary) a dossier to substantiate this.
In practice, this means a risk-based approach: first looking at existing knowledge, literature and historical data. Only when that does not provide sufficient clarity should one proceed to additional studies such as predictive microbiology or challenge tests. For companies with an extensive product portfolio, this can therefore be a phased process, with prioritisation based on risk.
Important to remember: the less substantiation, the greater the risk during inspections. Companies that bring a product to market after 1 July 2026 under the more lenient criterion without sufficient scientific substantiation will be in a weak position vis-Ã -vis the competent authorities.
Why this tightening of the rules?
This change did not come out of nowhere. The number of reported listeriosis cases in the EU has been rising in recent years, with a peak in 2023. Listeriosis primarily affects vulnerable groups such as pregnant women, the elderly, young children and people with weakened immune systems, and can have serious consequences for them.
What does this mean for your business?
High time to check, if not already done:
- which of your products fall under the new rules
- whether you have sufficient substantiation to demonstrate that a product does or does not support Listeria growth
- whether your shelf-life studies, monitoring programmes and any challenge tests are in order or need to be initiated.
Eurofins Food Testing is ready to guide you through this process, from initial risk assessment to the execution of the necessary studies and tests.
Summary
As of 1 July 2026, stricter rules apply for Listeria monocytogenes in ready-to-eat products (Regulation (EU) 2024/2895). This concerns products that can support Listeria growth, such as smoked fish, raw milk cheeses, deli meats and ready-to-eat salads.
- Regulation
- Cannot growth be substantiated? Then the rule is: absence in 25 g throughout the entire shelf life. (excl. exceptions)
- Can growth be substantiated? Then the more lenient criterion of max. 100 cfu/g continues to apply. (excl. exceptions)
- New: this responsibility extends until the end of the shelf life, not only until the product leaves the factory.
- Procedure: Not every product needs to have a fully completed challenge test by 1 July: a substantiated, risk-based approach is the starting point. The less substantiation, the greater the risk during inspections by the competent authorities.
