Thanks for the reply. Below is a definition from the USDA and a link to their website. Processed foods can be both RTE or Non RTE in the US, but if you are buying a processed food from a supplier, they must control the food safety risks in their HACCP/Food Safety plan. We do no rely on the end user to be the only control point regarding food safety. Since this supplied material is also being handled and re-packed by the company, they must source a material that is Listeria free so that they do not put their own facility at risk when handling the product. This should be identified in their HACCP/Food safety Plan as a serious risk (CCP, etc...) that is being pro actively managed by the supplier via a written specification agreement and Certificate of Analysis for each Lot # delivered. It is unrealistic to expect a material such as this to have no guaranteed pathogen control at the supplier level. Their Customer is demanding a Listeria free product to be supplied due to their High Risk situation. How else would you recommend this to be managed if not at the Supplier level?
In addition, all of my comments are absolutely correct as related to the US. Raw is raw. Pretty simple. Processed is defined below. In fact, most factories that I have worked for that process "raw" beef, chicken' seafood, vegetables, etc... have separate receiving areas in their facility and heightened GMP's and sanitation controls to manage the potential for cross contamination and to protect the materials that have already been "processed". In addition, "raw" products in the US are also required to be Pathogen Free upon release for sale. Examples of this include raw ground beef, for example, that is constantly being recalled in the US for e.Coli, recalls for "Raw" flour for containing e.Coli, Salmonella, etc.. and so on.
Processed foods defined
According to the United States Department of Agriculture (USDA), processed food is defined as any raw agricultural commodity that has been subject to washing, cleaning, milling, cutting, chopping, heating, pasteurizing, blanching, cooking, canning, freezing, drying, dehydrating, mixing, packaging or other procedures that alter the food from its natural state. This may include the addition of other ingredients to the food, such as preservatives, flavors, nutrients and other food additives or substances approved for use in food products, such as salt, sugars and fats.
Thank you again for your reply. If there is anything else that I need to clarify, please let me know.
Thks yr comments. It is possible that Semantics are confusing the Science.
Just for micro. accuracy, note that despite the Public (and occasionally Official) popularity, "Listeria" is not, per se, a pathogen, L.monocytogenes is a pathogenic species.
Afaik, in the USA, Regulatory controls are particularly oriented to the category of RTE foods. It is well-known , I think, that the USFDA Regulatory Policy for L.monocytogenes in RTE foods is, nowadays, Globally unique.
Publications/opinions issued by FDA and USDA are well-known to be discordant in certain areas regarding their interpretation/delineation of RTE products. A recent review of the (convoluted) development of USA's viewpoints is attached for those wishing to give themselves a substantial headache -
Risk Management for L.mono in foods,2021.pdf 2.16MB
(eg see Pgs 3-5)
Returning to the OP, my Post 3 remains unanswered with respect to RTE. I will assume product is commercialized as RTE.
afai can tell, the OP's product would fall within the jurisdiction of USFDA.
I attach the most recent (Producer's) appraisal of the US/FDA situation regarding RTE Fresh Produce. L.monocytogenes is predictably regarded as a zero-tolerant pathogen for this product however the text also contains, inter alia, these notable comments -
Finished product testing: Routine finished product testing can be of limited value due to the uneven distribution of the organism [L.monocytogenes] in a lot of product and the low frequency of occurrence of the organism of concern. Additionally, a product that tests positive for L. monocytogenes may be the result of contamination that occurred within the facility (which should have been detected by a robust environmental monitoring plan) or could be the result of unavoidable contamination in the growing environment. Therefore, although FDA recommends testing finished product on a periodic basis, XYZ recommends product testing in limited circumstances.
A facility may decide to test finished product resulting from a positive result in Zone 1 or as verification of the effectiveness of the environmental monitoring program. FDA draft guidance recommends that products be sampled for L. monocytogenes specifically, and not Listeria spp. This is especially valid for fresh produce items that lack a kill step; Listeria spp. is more likely to be positive than the pathogen, and presence of spp. does not render the product adulterated.
Listeria-Guidance within the Fresh Produce Industry,2018.pdf 1.83MB
(Earlier  indications of caveats regarding RTE fresh produce were elaborated in this response to FDA's draft guidance material -
Comments on FDA-Lm Guidance for RTE foods,2017.pdf 930.54KB
PS - I have avoided discussion of NRTE products since presumably OT.
If you can reference a USFDA or USDA statement concerning a designated "raw" finished product which is intended (eg labeled) to be fully cooked by the consumer and is Regulatory associated with a zero-tolerance for L.monocytogenes I will be interested, albeit extremely surprised.
(JFI such a requirement was in fact introduced by USFDA for imported "raw" frozen shrimp around 3 decades ago. It was repealed within 12 months due the avalanche of rejections for what was shortly recognized as an environmentally ubiquitous (ie unavoidable) microorganism. Afaik this remains the current situation.)