Israel has implemented updated public health protections for food additives and food safety annex II listings, aligning with EU directives through new regulatory notices.
Israel Aligns Food Additive Rules with EU Standards
New restrictions on common additives affect products traded with the EU.
What changed
Food additive restrictions updated for sodium benzoate, potassium sorbate, and monosodium glutamate under EU Regulation 1333/2008.
Annex II foodstuffs list revised with new microbiological criteria for food hygiene and additive safety.
Artificial flavoring oversight expanded under EU Regulation 2073/2005 hygiene and safety thresholds.
HS codes 210690 and 481910 affected by the new additive and safety requirements.
Who it affects
Food importers and exporters trading between Israel and the EU must comply with updated additive standards.
Food manufacturers using sodium benzoate, potassium sorbate, or MSG must reformulate to meet new limits.
Producers of HS 210690 and 481910 products must verify microbiological criteria compliance.
What to do
Review product formulations against EU Regulation 1333/2008 additive limits.
Update microbiological testing protocols to meet Annex II criteria.
Verify compliance for products under HS codes 210690 and 481910.
Regulation Analysis: Israel’s Updated Microbiological Criteria for Foodstuffs Aligning with EU Regulation 2073/2005
Israel has adopted EU Regulation No. 2073/2005 on microbiological criteria for foodstuffs through the Public Health Protection (Food) Notice (Application of Changes to the Annex to the European Union Directives) (Regulation 2073/2005 – Concerning Microbiological Criteria for Foodstuff), 5785-2025, with specific modifications and exclusions. The key changes focus on stricter Listeria monocytogenes criteria for ready-to-eat (RTE) foods, effective 1 July 2026, while retaining certain deviations from the EU’s full requirements.
1. Legal Framework and Adoption of EU Regulation 2073/2005
Israel’s adoption of EU Regulation 2073/2005 is governed by:
- Protection of Public Health (Food) Law, 5776-2015 (Amendment No. 3)1, which incorporates the EU regulation via Appendix II A, Item 3.
- Amendment No. 10 to the Food Law (2024), which re-adopted the EU regulation as in force on 8 March 20201.
- The Public Health Protection (Food) Notice (5785-2025), which implements the latest EU amendments (EU 2024/2895) with Israeli-specific exclusions1.
Key Authority: The Israel National Food Service (Ministry of Health) is responsible for enforcement1.
2. Core Requirements and Modifications
A. Microbiological Criteria for Listeria monocytogenes
The primary update aligns with EU 2024/2895, introducing stricter criteria for RTE foods (excluding infant foods and special medical purposes):
- Default Requirement: "Listeria monocytogenes not detected in 25 grams" throughout shelf life1.
- Exception: If the food business operator (FBO) can demonstrate to the competent authority that Listeria monocytogenes will not exceed 100 cfu/g over the product’s shelf life, the less stringent limit applies1.
- Effective Date: 1 July 20261.
B. Israeli-Specific Exclusions and Modifications
Despite adopting EU 2073/2005, Israel retains deviations listed in:
- Columns A and C of Item 3, Second Appendix A to the Food Law1.
- Section 3a(a1)–(a5) of the Protection of Public Health (Food) Law, 5776-2015, which outline exceptions1.
Notable Exclusion:
- For Chapter 1 of Annex I (EU 2073/2005), details 1.2 and 1.3, Israel replaces the EU’s "100 cfu/g" limit with "not detected in 25 grams"1. This renders the EU’s 2024 amendment (EU 2024/2895) practically irrelevant for these categories in Israel1.
C. Exempted Products
The regulation does not apply to:
- Raw meat,
- Raw milk,
- Honey,
- Fresh eggs in their shells1.
3. Compliance Timeline and Stakeholder Actions
| Milestone | Date | Action Required | Authority |
|---|---|---|---|
| Publication of Notice | 17 August 2025 | Stakeholders may review the draft regulation1. | Israel National Food Service |
| Comment Period Ends | 19 December 2025 | Final date for submitting feedback to the National Enquiry Point1. | Ministry of Health |
| Entry into Force | 1 July 2026 | Full compliance with updated Listeria monocytogenes criteria required1. | Israel National Food Service |
4. Summary Table of Key Requirements
| Regulation | Key Requirement | Threshold/Deadline | Authority |
|---|---|---|---|
| EU Regulation 2073/2005 (as adopted in Israel)1 | Microbiological criteria for foodstuffs, including Listeria monocytogenes limits for RTE foods. | Effective 1 July 2026 | Israel National Food Service |
| Public Health Protection (Food) Notice (5785-2025)1 | Adopts EU 2024/2895 amendments but retains Israeli exclusions (e.g., "not detected in 25g" for Annex I, Chapter 1.2–1.3). | Published 17 August 2025 | Ministry of Health |
| Protection of Public Health (Food) Law, 5776-2015 (Amendment No. 3)1 | Legal basis for incorporating EU 2073/2005 via Appendix II A, Item 3, with exceptions in Section 3a(a1)–(a5). | In force | Knesset |
| Exclusion in Column C (Second Appendix A, Item 3)1 | Overrides EU’s "100 cfu/g" limit for Listeria monocytogenes in specified RTE foods, replacing it with "not detected in 25g". | Applies indefinitely | Israel National Food Service |
5. Summary Answer
Israel has aligned its microbiological criteria for foodstuffs with EU Regulation 2073/2005, as amended by EU 2024/2895, through the Public Health Protection (Food) Notice (5785-2025)1. The key change imposes a default requirement of "Listeria monocytogenes not detected in 25 grams" for ready-to-eat foods (excluding infant/special medical foods), effective 1 July 20261. However, Israel retains specific exclusions (e.g., stricter limits for Annex I, Chapter 1.2–1.3) that deviate from the EU’s full requirements1. Exempted products include raw meat, raw milk, honey, and fresh eggs1. Stakeholders must comply by the 2026 deadline, with a comment period open until 19 December 20251. The Israel National Food Service (Ministry of Health) is the enforcing authority1.
Sources
- ↩ Public Health Protection (Food) Notice (Application of Changes to the Annex to the European Union Directives) (Regulation 2073/2005 – Concerning Microbiological Criteria for Foodstuff), 5785-2025 https://docs.wto.org/dol2fe/Pages/SS/directdoc.aspx?filename=Q:/G/SPS/NISR11.pdf&Open=True