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With the implementation of from 1 July 2026, manufacturers of ready-to-eat (RTE) foods will be required to demonstrate more rigorously whether their products are capable of supporting the growth of Listeria monocytogenes throughout their shelf life.
To perform this assessment, the legislation assigns a fundamental role to two physicochemical parameters: water activity (aw) and pH. Water activity indicates the amount of water available for microbial growth, while pH reflects the acidity of the food. Both factors have a direct impact on the ability of Listeria monocytogenes to grow and, consequently, on the level of risk associated with the product. In fact, Regulation (EC) No 2073/2005, as amended by Regulation (EU) 2024/2895, specifies that certain ready-to-eat foods are considered unable to support the growth of Listeria monocytogenes when they meet one of the following criteria:
• pH ≤ 4.4
• aw ≤ 0.92
• pH ≤ 5.0 in combination with aw ≤ 0.94
• A shelf life of less than 5 days
• Other product categories for which the food business operator can scientifically demonstrate that growth of the microorganism will not occur
When a product meets any of these criteria, the risk of Listeria monocytogenes proliferation is considered very limited. However, foods exceeding these thresholds may be classified as products capable of supporting the growth of the pathogen. In such cases, more stringent microbiological control requirements apply, and manufacturers must provide evidence demonstrating that the product remains safe throughout its shelf life. For this reason, the determination of water activity and pH has become an essential tool for the food industry. These analyses enable manufacturers to correctly classify their products, support shelf-life studies, design appropriate preservation strategies, and generate the documentation required, through a science-based approach, to demonstrate compliance with regulatory requirements.
YOUR PLUS: At AGROLAB, we offer accredited water activity and pH testing, together with technical support for the microbiological assessment of ready-to-eat foods and compliance with the requirements established for Listeria monocytogenes.
Author: Dr Isabel Gómez, Agroha Iberia
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