HyV Revision 2025: Stricter requirements for ready-to-eat foods
According to the European Union OneHealth Zoonosis report by the European Food Safety Authority (EFSA), foodborne listeriosis cases increased significantly between 2019 and 2023. Most cases are attributed to the consumption of products made from raw meat, fish, milk, or cheese, or fruit and vegetables that are not heat-treated during production or prior to consumption.
Listeriosis is caused by the bacterium Listeria monocytogenes, a common contaminant in ready-to-eat foods. In the human body, L. monocytogenes is taken up by macrophages and multiplies intracellularly. In individuals with a weakened or underdeveloped immune system, L. monocytogenes can cross the body's protective barriers, such as the blood-brain barrier and the placenta. At-risk groups therefore include very young children, elderly or immunocompromised individuals, and pregnant women.
To help prevent risk to consumers, the Swiss food law defines limits for L. monocytogenes in the Federal Department of Home Affairs (FDHA) Ordinance on Hygiene in the Handling of Foodstuffs (HyV). These apply to ready-to-eat foods intended for infants or for special medical purposes, and to food categories 1.2* and 1.3**.
Until now, the criterion for ready-to-eat foods that may support the growth of L. monocytogenes (category 1.2) was "not detectable in 25 grams" up until the product leaves the manufacturer's premises and is no longer under their direct control. At the retail level, foods in category 1.2 were permitted to contain up to 100 colony-forming units per gram (CFU/g).
Under the new rules, the limit "not detectable in 25 grams" applies to category 1.2 foods throughout their entire shelf life in retail, and therefore beyond the point at which they leave the manufacturer. However, if the manufacturer can provide scientific evidence, such as a challenge test, demonstrating that L. monocytogenes does not grow beyond 100 CFU/g during the product’s shelf life, the limit of 100 CFU/g remains applicable until the use-by date.
These stricter limits for food category 1.2 place greater responsibility on food manufacturers to demonstrate the microbiological safety of their products through challenge tests. The aim of such tests is to determine the growth potential of L. monocytogenes under representative conditions, through a microbiological shelf-life study. The results serve as a scientifically sound basis for decisions on applying limits within food category 1.2.
These revised legal requirements in the HyV entered into force on 1st July 2025, with a one-year transition period until 30th June 2026, and are intended to strengthen the protection of public health in light of the increasing number of listeriosis cases.
Our Eurofins Food & Feed Testing laboratories in Switzerland are happy to support you with expert and comprehensive advice on all questions relating to the new legislation.
* ready-to-eat foods that may support the growth of L. monocytogenes
** ready-to-eat foods that do not support the growth of L. monocytogenes