CFA publishes timely new industry-led UK Ready to Eat Foods Safety and Shelf Life Guidance

New industry-led good practice guidance for manufacturers and retailers of certain ready to eat (RTE) foods will be published on 12 January 2026 to help Food Business Operators (FBOs), Competent Authorities (CAs) and enforcement officers manage the risk posed by Listeria monocytogenes in those products.

The guidance (https://bit.ly/4rtqmLI), which was developed by the Chilled food Association (CFA) in consultation with regulators and industry, reiterates that food safety must be assured through HACCP, supported by Good Manufacturing Practice (GMP), Good Hygienic Practice (GHP) and Pre-Requisite Programs (PRPs).

READ MORE: Meet the Advisory Groups: Our Q&A with Karin Goodburn

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The guidance is timed to help prepare businesses for a change to the EU Regulation, applicable from 1 July 2026 in the EU and other jurisdictions applying EU law including Northern Ireland. It explains how to assure food safety with respect to L. monocytogenes including setting and evidencing shelf life and compliance with the amendment to criterion 1.2b brought in by Regulation 2024/2895. The 1 July change will apply where shelf life evidence for RTE foods supporting the growth of L. monocytogenes is deemed insufficient by CAs.

Significant update

The document is a significant update of shelf life guidance issued by CFA in conjunction with a range of other food trade associations and FSA in 2010. It will be welcomed by all who have been seeking clarification on the potential impacts of the changes to the Regulation. Clarification is offered on key points including:

• HACCP is mandatory as the foundation for food safety; HACCP plans must be demonstrably supported by robust GHP, GMP and PRPs.
• Listeria monocytogenes is the only Listeria species regulated because of its ability to cause serious human disease and to survive and grow under chilled conditions.

• There are no changes to fundamental legislated food safety assurance requirements including shelf life determination.

• There is no standard method to estimate or set the shelf-life of a food product because there are many different factors that can affect the product safety and quality. Detail is given on approaches to be followed together with limitations and special considerations, data usage, and the application of the legislation in the context of HACCP.
• Shelf life decisions must be evidence-based and take into account physicochemical parameters, the behaviour of all relevant microorganisms, intended consumers (including vulnerable groups), historical HACCP and Food Safety Management System data including food sampling and other shelf life study data where appropriate.

• Environmental monitoring and ingredient controls are essential components of a preventive strategy for Listeria monocytogenes; detections in the environment or ingredients must trigger defined corrective actions.
• Support for enforcement by clarifying expectations for sampling, interpretation of results, and actions when L. monocytogenes is detected at different levels in ingredients or finished products.

The guidance has been specifically developed for: manufacturers and retailers of RTE foods that may support growth of L. monocytogenes, with the exception of foods intended for infants or for special medical purposes; Competent Authorities and enforcement officers seeking a practical reference for inspection and enforcement and supply chain partners and trade associations advising members on compliance with microbiological criteria and evolving regulatory requirements.

Easy to apply

Developed in direct response to questions and concerns the guidance is designed to be easy to apply, comprising a range of practical resources and case studies:

• Decision tree to determine applicability of the guidance.
• Tables summarising microbiological criteria and the amended criterion 1.2b.
• Checklists for purchasing RTE ingredients.
• Environmental monitoring programme design and usage.
• Detailed approaches to establishing and justifying shelf life (physicochemical data, scientific and historical data, experimental studies).
• Worked shelf life examples (e.g., cheese and sandwich scenarios).
• Usage and limitations of predictive modelling, durability and challenge testing.
• Example types of historical data to be collated by FBOs in support of food safety assurance and shelf life.
• Q&A addressing common operational questions and enforcement scenarios.

The guidance references the Microbiological Criteria for Foodstuffs Regulation 2073/2005 (as amended) and the amendment introduced by EU Regulation 2024/2895 (criterion 1.2b), which applies in the EU and in jurisdictions applying EU law from 1 July 2026.

In the UK context, references to EU legislation should be read as applying to Northern Ireland as EU law and to England, Wales and Scotland as assimilated law where relevant.

As with previous versions the guidance will be updated in light of practical experience and regulatory developments; feedback from industry and enforcement bodies is welcomed.

Bringing clarity

Karin Goodburn MBE, Chair, Industry Listeria Group, Chilled Food Association, and a member of AMI’s Food Security Advisory Group, said: “This vital guidance brings practical clarity to the steps manufacturers and other FBOs must take to assure the safety of RTE foods with respect to L. monocytogenes including how to establish and evidence shelf life.

”It places prevention at the centre of operations with strong HACCP, backed by good hygiene and robust prerequisite programs and gives clear direction on how to set shelf life, how to respond to detections of L. monocytogenes and how to use environmental monitoring program data to support food safety.

“We believe the guidance gives FBOs the necessary tools to enable them to review and, where necessary, update HACCP plans and PRPs to reflect the guidance as well as ensure shelf life justifications are documented and supported by appropriate data. It will also allow them to strengthen environmental monitoring and supplier controls and seek technical expertise if internal capability is insufficient.

“We are grateful for the input and support of member organisations of the Industry Listeria Group, the Food Standards Agency and Food Standards Scotland.”

Industry-led guidance

James Cooper, Deputy Director of Food Policy, Food Standards Agency and Gary Mournian, Head of Policy and Regulatory Affairs, Food Standards Scotland, said: “We welcome this updated industry-led guidance, which provides practical advice to help food businesses manage the risk of Listeria monocytogenes in ready-to-eat foods.

“Assuring food safety through robust HACCP systems, good hygiene practices, and evidence-based shelf-life determination is essential to protect consumers, particularly vulnerable groups. This guidance will support manufacturers, retailers, and enforcement officers in meeting regulatory requirements and maintaining high standards of food safety.”

Bronwen Percival, Technical Committee Chair, Specialist Cheesemakers Association, said: “We welcomed the chance to work with the FSA to bring clarity to the process of setting shelf life. For cheesemakers producing soft cheeses where Listeria can grow, the rules can feel daunting. Clear guidance on best practice is a win for everyone. For cheesemakers, establishing shelf life on certain products can be complex. Working with the FSA to clarify expectations supports producers and protects consumers: exactly what we’re here for.”

Valuable resource

Devina Sankhla, Food Policy Advisor at the British Retail Consortium (BRC), said: ”The BRC is pleased to support and endorse this revised guidance. It is a valuable resource for food businesses and enforcement, providing clear and practical advice to support compliance with food hygiene and food standards in relation to the management of Listeria monocytogenes in chilled food production of ready to eat products.

Copies of the guidance are available from www.chilledfood.org/shop from 12 January 2026.