Feedback reference
Submitted by
Camille PERRIN
User type
Consumer organisation
BEUC - The European Consumer Organisation
Organisation size
Small (10 to 49 employees)
Transparency register number
Country of origin

BEUC, The European Consumer Organisation, wishes to provide comments on the draft Commission Regulation authorising the use of Listex™ P100 on ready-to-eat (RTE) food of animal origin to reduce contamination with Listeria monocytogenes.

BEUC generally disapproves of the use of ‘decontamination’ treatments as we are concerned they may result in a lowering of EU hygiene standards. Less scrupulous food business operators might see them as a convenient substitute for good husbandry and hygienic practices on farm and in the abattoir. Moreover, many of these treatments are of questionable efficacy and bacteria can develop resistance to them.

While EFSA found that Listex™ P100 itself does not raise any food safety concern, its verdict on the efficacy of this treatment is much more mitigated. First, between 2.5% and 9.5% of naturally occurring Listeria strains exhibit resistance to bacteriophage P100. Second, the efficacy of Listex™ P100 in a real-life setting is not well demonstrated. EFSA noted that “there were very limited data on the effect of Listex™ P100 on RTE foods naturally contaminated with L. monocytogenes” and stated that “predictions of the magnitude of the efficacy of Listex™ P100 in reducing L. monocytogenes contamination of RTE foods in specific processing plants are highly uncertain”.

EFSA also warned that “P100-resistant variants [of Listeria monocytogenes] might be selected as a consequence of its use in industrial settings” in the absence of proper cleaning and disinfection of the areas where Listex™ P100 is used and/or in case it is not used properly. This might put consumers’ health at risk, especially if food businesses have lowered their guard on good hygiene and instead over-rely on decontamination with Listex™ P100.

Finally, from the consumer perspective, we would insist that Listex™ P100, if at all authorised, should be labelled. The effect of Listex™ P100 persists during storage and therefore it should be considered as a food additive, and not as a processing aid. This answer by the European Commission to a
parliamentary question from 2007 on Listex™ P100 shows that the status of this treatment (additive vs. processing aid) is far from clear-cut. As far as we can see, the annex to the draft Regulation specifying the conditions of use of Listex™ P100 does not foresee any specific processing step to rinse off/remove the treatment after it has been used. Consequently, we question its classification as a processing aid (under Regulation (EC) 853/2004 on the hygiene of foodstuffs of animal origin) and believe it should be considered as a food additive.

We thank you in advance for taking our comments into consideration and remain at your disposal, should you wish to discuss this further.

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