Israel Updates Food Additives and Safety Standards

Israel has updated its food additive and safety regulations to align with European Union directives, specifically targeting food additives, food hygiene products, and food safety annex II listings

Regulation Analysis: Israel’s Adoption of EU Microbiological Criteria for Foodstuffs (Regulation 2073/2005)

Israel has aligned its food safety regulations with EU Regulation No. 2073/2005 on microbiological criteria for foodstuffs, incorporating key amendments while maintaining specific national deviations. The primary update introduces stricter Listeria monocytogenes controls for ready-to-eat (RTE) foods, effective 1 July 2026, but retains Israel-specific exclusions outlined in Appendix II A of the Public Health Protection (Food) Law, 5776-2015.

1. Key Regulatory Framework

1.1 Legal Basis

• Primary Law: The Public Health Protection (Food) Law, 5776-2015 (Amendment No. 3 and No. 10) serves as the foundation for adopting EU microbiological criteria¹.
• Secondary Legislation: The Public Health Protection (Food) Notice (Application of Changes to the Annex to the European Union Directives) (Regulation 2073/2005), 5785-2025 implements the EU regulation with Israel-specific modifications¹.
• Adoption Mechanism: EU Regulation 2073/2005 was incorporated via:
  • Economic Plan Law (2021–2022) (indirect amendment to the Food Law)¹.
  • Amendment No. 10 to the Food Law (published 4 August 2024), adopting the EU regulation as of its 8 March 2020 version¹.

1.2 Scope of Application

• Covered Products:
  • All foodstuffs subject to microbiological criteria, except:
  • Raw meat, raw milk, honey, and fresh eggs in their shells¹.
  • ICS Codes: 67.040 (food microbiology) and 67.050 (general food testing methods)¹.
• Exclusions: Israel retains deviations listed in columns A and C of Item 3, Appendix II A of the Food Law, as well as section 3a(a1)–(a5)¹.

2. Core Requirements

2.1 Microbiological Criteria for Listeria monocytogenes

The most significant update aligns Israel with EU Regulation 2024/2895 (published 20 November 2024), introducing a two-tiered standard for RTE foods (excluding infant formula and medical-purpose foods):

• Effective Date: 1 July 2026¹.
• Competent Authority: Israel National Food Service (Ministry of Health)¹.

2.2 Israel-Specific Deviations

Despite adopting EU Regulation 2073/2005, Israel maintains the following national modifications:

1. Appendix II A, Item 3 (Columns A and C):
   • Column C overrides EU Annex I, Chapter 1 (1.2 and 1.3), replacing the 100 cfu/g limit with "not detected in 25g" for certain RTE foods¹.
   • This deviation nullifies the practical impact of the EU’s 2024 amendment for Israel, as the stricter national standard already applies¹.
2. Section 3a(a1)–(a5) of the Food Law:
   • Additional exemptions or procedural flexibilities (details not specified in sources)¹.

3. Implementation Timeline

4. Compliance Obligations for Food Business Operators (FBOs)

1. Testing Requirements:
   • FBOs must conduct microbiological testing for L. monocytogenes in RTE foods, adhering to the 25g detection limit unless exempted under Appendix II A¹.
   • Shelf-life validation: FBOs must demonstrate compliance throughout the product’s shelf life¹.
2. Documentation:
   • FBOs must maintain records proving control measures (e.g., process validation, testing results) to justify the ≤100 cfu/g limit if challenged by authorities¹.
3. Exemptions:
   • Raw meat, raw milk, honey, and shell eggs are excluded from these criteria¹.
   • Other exclusions apply per Appendix II A and section 3a(a1)–(a5)¹.

5. Enforcement and Oversight

• Responsible Authority: Israel National Food Service (Ministry of Health)¹.
• Contact for Queries:
  • Email: michal.sela@moh.gov.il¹.
• Non-Compliance Consequences: Not specified in sources, but likely subject to penalties under the Public Health Protection (Food) Law, 5776-2015.

Summary Answer

Israel has adopted EU Regulation 2073/2005 on microbiological criteria for foodstuffs, with key updates effective 1 July 2026, including stricter Listeria monocytogenes controls for ready-to-eat foods (≤100 cfu/g or "not detected in 25g" depending on FBO validation)¹. However, Israel retains national deviations in Appendix II A and section 3a(a1)–(a5) of the Food Law, which override certain EU provisions (e.g., the 25g detection limit already applies to specific RTE foods)¹. The regulation excludes raw meat, raw milk, honey, and shell eggs¹. Compliance requires FBOs to validate shelf-life safety and maintain testing records¹. The Israel National Food Service oversees implementation, with a comment period closing 19 December 2025¹.

Sources

1. ↩ 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