Listeria: from 1 July 2026, zero becomes the standard

The reasoning behind it is as sober as it is concerning. The European Food Safety Authority has seen the number of listeria infections rise, in 2022 it was almost 16% higher than the year before, and listeriosis remains, year after year, the deadliest zoonosis in the EU, with the highest hospitalisation and mortality rates. Add to that earlier discussions on interpretation, such as the case concerning salmon and trout in Estonia, and the Commission's conclusion was clear: the old criteria offered insufficient protection, especially for the most vulnerable consumers. The answer to this is Regulation (EU) 2024/2895, which tightens Regulation 2073/2005.

What exactly is changing?

Previously, "not detected in 25 g" was only a release criterion: it applied only while the product remained under the producer's direct control, and only when the producer could not demonstrate that the product would stay below 100 cfu/g throughout its entire shelf life. If that evidence was successfully provided, the limit of 100 cfu/g simply applied, even once the product was on the market.

Since 1 July 2026, that logic has been reversed. "Not detected in 25 g" becomes the standard for the entire shelf life. If you want to fall back on the margin of up to 100 cfu/g, you need to substantiate this with evidence accepted by the competent authorities.

What does this mean for you?

In short: the bar is higher, and it applies to everyone in the chain.

• The standard now applies over the entire shelf life, not just at the moment of dispatch.
• Responsibility shifts to the entire chain: production, distribution and retail.
• "Not detectable in 25 g" becomes the default. Zero tolerance is the starting point.
• Deviating to 100 cfu/g is only possible with robust, validated evidence accepted by the authorities showing that growth remains under control.
• For some products, reformulation or launching additional studies and challenge tests may become the smartest route.
• European rules are being further harmonised and made stricter.
• Exceeding the limit generally results in an immediate recall.

The common thread is clear: this is a shift from a predominantly risk-based approach to a mandatory, preventive standards framework. No longer reacting when something goes wrong, but demonstrating in advance that it cannot go wrong.

Threat or head start?

This is where the choice lies. You can see this change as an operational, economic and technical burden, and to be fair, that side does exist. Or you can see it for what it also is: an opportunity to future-proof your management system now, before an inspection or a recall makes that choice for you.

Companies that review and strengthen their validations in good time, that have their challenge tests in order and can demonstrate that the growth of Listeria monocytogenes is effectively controlled throughout the entire shelf life, will not be left playing catch-up. 

Are you already compliant with the new standard?

The standard is now in force, and building a solid dossier (studies, challenge tests, watertight substantiation) takes time. Haven't started yet? Then now is the moment to get compliant.

We're happy to think it through with you: from an initial risk assessment to a well-substantiated, audit-proof dossier that stands rock solid.

Want to know where your products stand today against the new standard? Schedule a no-obligation consultation and we'll take the first step together.