Update change TGT and THT entry

For several years there has been a discussion in the EU about the labeling of best-before dates. When the 2020 Farm to Fork strategy was released, it became clear that some things will change in terms of labeling. One of the stumbling blocks is the use of "TGT" and "THT" as best-before dates. The Netherlands also announced to adjust national legislation. What exactly is going on and what will change?

Food Waste

One of the main focuses of the European Green Deal and the Farm to Fork strategy is sustainability. Several sub-goals should help the EU become more sustainable, and food waste is an important pillar in this. The goal is to reduce food waste caused by consumers and retail by 50% by 2030.

According to research commissioned by the European Commission, the way shelf life dates are stated is responsible for 10% of consumer food waste[1]. This, according to consumer research, is thought to be because the difference between "use by" and "best before" is not understood enough. This results in consumers throwing away products with a THT date even though they can still be safely consumed after the expiration date.

Dutch law

In the Netherlands, Article 15 of the Warenwetbesluit Bereiding en Behandeling van Levensmiddelen (Commodities Act Decree on the Preparation and Treatment of Foodstuffs) currently regulates when a THT and when a TGT must be stated. This article was basically the same for 20 years: products that had a storage temperature between 0 and 6 degrees or products with a shelf life of less than 5 days had to have a TGT statement. Other products were given a THT.

Last February 23, it was announced how this Commodities Act decree will be adjusted, this change will take effect on July 1. The purpose of the adjustment in the area of best-before dates is to align national legislation with European legislation. The Dutch legislator not only makes a reference to how national rules have become redundant, but also to confusing situations for consumers. The confusion for consumers lies in the fact that one product has a THT, while the same product of another brand has a TGT. This would be the case, for example, when one product has a shelf life of 4 days and another product has a shelf life of 5 days.

Examples cited in the RDW report are: "particularly processed meats (filet americain, raw ham), fish 'ready-to-eat' (mackerel, salmon), ready-to-eat meals, pre-packaged salads, pre-cut fruit, sprouts, and pre-cut/pre-packaged vegetables that can be eaten raw (carrots, radishes)." Moreover, it is not true that only products with a storage temperature between 0 and 6 degrees and with a shelf life of less than 5 days are unsafe after expiration.

European legislation

So national legislation adapts to European legislation. So what exactly does the European legislation say? According to Article 24 of the 1169/2011, a product should have a TGT statement when, from a microbiological point of view, they are highly perishable and may pose an immediate danger to human health. Thus, the producer decides whether a product needs a TGT or THT. The basic principle is that the product must present a hazard and that this hazard must come from pathogenic bacteria. As a result, food producers must watch carefully what happens after the expiration date: does the product become unsafe (immediately or after a short time) or do quality problems occur? In the case of an unsafe product, the product is given a TGT, in the case of a quality problem, a THT. For products that are safe for a long time after the expiration date, nothing changes. Products that quickly become unsafe, but have a shelf life longer than 4 days or are stored above 6 degrees, can now also be given a TGT. So this is all about the presence of pathogenic bacteria. It is important to determine case-by-case what applies to which product.

New proposal

A new proposal is expected from the European Commission in Q4 of 2022. In recent years, they have been researching how legislation should be adjusted to prevent food waste caused by shelf life indications. Once this proposal is there, it will take some time before it will be implemented. We will keep you informed!