Starting from July 1, 2026, the European Union (EU) applies new regulations on controlling Listeria monocytogenes bacteria against ready-to-eat food, requesting seafood enterprises to prove products are safe throughout their shelf lives. The regulation is projected to significantly impact enterprises exporting processed seafood to the EU market.

Starting from July 1, 2026, the European Commission's Amending Regulation (EU) 2024/2895, amending Regulation (EC) No 2073/2005 on microbiological criteria for foodstuffs, officially enters into force. The notable point of alteration is expanding the responsibility for controlling Listeria monocytogenes bacteria against Ready-to-Eat (RTE) food from manufacturers to the entirety of subjects participating in the supply chain.

This move was made against a backdrop where the count of Listeria infections in Europe in 2022 rose by 15.9% compared to the previous year, while the count of deaths due to food poisoning related to this bacteria resided at the highest level within a decade.

Upgrading product safety proof requirements

According to previous regulations, enterprises merely had to prove not detecting Listeria monocytogenes within 25g of products at the timing the food left manufacturing facilities, if they could not prove that bacterial density remains consistently below the threshold of 100 CFU/g throughout the shelf life.

The new regulation has expanded this requirement. Accordingly, against ready-to-eat food products capable of generating conditions for Listeria to develop, enterprises must prove via scientific bases that bacterial content does not exceed 100 CFU/g during the entire shelf life under projected preservation conditions. If lacking sufficient evidence, the product is mandatory to satisfy stricter criteria of not detecting Listeria within 25g throughout its commercial life cycle.

Thus, the EU does not simply switch to a "zero tolerance" policy against all ready-to-eat food but places the focus on the control and safety proof capacities of enterprises through scientific data and technical dossiers.

How are seafood enterprises impacted?

According to the Vietnam Association of Seafood Exporters and Producers (VASEP), the new regulation does not apply against the entirety of seafood products exported to the EU.

Live fresh, frozen seafood products or products clearly stated to be cooked before utilizing will not belong to the group bearing direct impacts of the regulation. However, ready-to-eat products, pre-processed products, or those that can be utilized directly without requiring re-heating will have to satisfy stricter control requirements.

The cause is that Listeria monocytogenes bacteria possess the capacity to survive and develop even under cold preservation conditions, particularly against products carrying long shelf lives, high moisture, or vacuum packaging.

Accordingly, merely testing finished products prior to leaving factories will no longer be sufficient. Enterprises must construct scientific dossiers proving products still guarantee safety throughout the circulation and consumption processes.

Technical dossiers will become a mandatory requirement

To support enterprises executing the new regulation, the European Commission has promulgated guidelines regarding Listeria monitoring and shelf-life studies against ready-to-eat food.

Meanwhile, the Food Safety Authority of Ireland (FSAI) also recommended enterprises to strengthen food safety management systems, because testing methods under the new standard carry higher sensitivity and the risk of product recalls will escalate if risks are not controlled well.

Against Vietnamese seafood exporting enterprises, importers and retail systems in the EU can request supplementing multiple technical documents such as: shelf-life studies, production environment monitoring data, sampling plans, sanitation verification results, post-heating control dossiers, and evidence of maintaining cold chains throughout the transportation process.

Proactively adapting to firmly maintain the EU market

Before the new requirements, VASEP recommends enterprises to urgently review export product catalogs to the EU, clearly classifying ready-to-eat and non-ready-to-eat food groups to apply correct standards.

Against ready-to-eat products carrying risks of Listeria development, enterprises need to re-evaluate shelf lives, preservation conditions, and construct full scientific dossiers proving products satisfy microbiological limits under regulations.

Besides, enterprises need to strengthen production environment monitoring programs, particularly at post-heating zones; reviewing HACCP plans, factory sanitation processes, and tightly controlling cold supply chains aiming to restrict re-contamination risks of bacteria.

In addition, commodity labels and user guides also need to be updated fully, guaranteeing reflecting correctly the nature of products. With products mandatory to be cooked prior to utilizing, enterprises need to clearly state heating instructions and preservation conditions to avoid being classified into the ready-to-eat food group.

According to experts, the EU's new regulation does not merely tighten microbiological criteria but also shifts the focus to quality governance capacities and the safety proof abilities of enterprises within the entire product life cycle. This serves both as a challenge and a driver for the Vietnamese seafood sector to elevate manufacturing standards, satisfying better the demands of high-end export markets, thereby reducing risks of being warned or having goods returned in the coming time.

Source: Tap chi Doanh nghiep va Hoi nhap