Higher bar with heavier loads

The NVWA is replacing Information Sheet 85 with the Food Microbiology Handbook. This handbook imposes stricter requirements on Listeria control, environmental testing and trend analysis. Much of this interpretation goes beyond what EU regulations strictly require. As a result, SMEs in particular face higher costs and more complex requirements without demonstrably improving food safety. The enforcement bar is higher than legally required.

In this article, we conveniently summarise the changes - with a particular focus on the provisions that as of 1 July 2026 take effect.

Main changes in design and content

What will change from 1 July 2026?

The amended EU regulation 2073/2005 comes into force on 1 July 2026. Main changes:

1. For ready-to-eat products in which Listeria can grow (category 1.2):
   • Is no shelf life study available? → then absence in 25 g is mandatory (n = 5, c = 0).
   • Is there a substantiated study? → then 100 cfu/g may be allowed, with additional conditions (such as intermediate limits).
2. Each batch should be sampled until a study is available.
3. Intermediate limit values (IGW) may be used provided the study explicitly justifies it.

Is the manual more stringent than Information Sheet 85?

Although the core obligations stem directly from EU legislation, the NVWA imposes an interpretation in the Handbook that in practice goes beyond what the law strictly requires. This mainly concerns the obligation to carry out extensive challenge testing (full TGD v4), trend analysis with detailed visualisations and extensive environmental monitoring. For larger companies, these extras are usually easy to fit in, but for SMEs, the cost and organisational burden pose a serious challenge. The bar is actually higher than necessary to meet the basic obligation under EU legislation. This can lead to disproportionate burden without demonstrable additional improvement in food safety.

What to do now?

1. Update studies in time. Have shelf-life studies for risk products carried out or updated before 1 July 2026. Work in a focused and practical manner: only where it is really necessary, according to TGD v4.
2. Keep trend analyses compact but demonstrable. Capture trends and substantiate actions, but avoid unnecessary complexity.
3. Apply environmental research where it counts. Focus on high-risk areas and document actions. Keep frequency and locations workable.
4. Arrange isolate management smartly. Make clear agreements with the lab on retention periods and availability to NVWA, without unnecessary burdens.
5. Use the Handbook deliberately. Think of it as a guideline; comply with the law, but avoid overimplementation.

Sources

• NVWA (2025). Handbook of food microbiology.
• NVWA (2021). Information sheet 85 - Interpretation of Regulation 2073/2005.
• European Commission (2024). Amendment of Regulation (EC) 2073/2005, published in OJEU.
• Technical Guidance Document v4 - EURL Lm (2021).
• Regulation (EC) 852/2004 and Directive 2003/99/EC.