6 replies to this topic

[Stacys]

Good Afternoon,

 

So there is always an argument here at our facility as to what is considered ready to eat. Going by the FDA it is anything you can take off the shelf, open and eat. We make Mushroom Coffee, Mix for ice cream etc. and we do not consider them ready to eat as they need to be mixed with other ingredients. 

This questions is being thrown out for clarification as on member is certain the items are ready to eat.

 

Stacy

[Apoorva Yogi]

According to the FDA Food Code and 21 CFR 117.3, a Ready-to-Eat food is: This includes:

 

any food that is in a form that is edible without additional preparation to achieve food safety."

• Foods that are normally eaten without cooking (e.g., deli meat, snack bars, yogurt).

• Foods that have already been processed to eliminate pathogens and require no further kill step.

• Processed or shelf-stable mixes if consumed without a validated kill step.

Not RTE (Generally Accepted as Needing a Kill Step):

• Mushroom Coffee (Dry Mix): Usually requires mixing with hot water, which serves as a kill step.
  → Not RTE, because the consumer will apply heat.

• Ice Cream Mix (Premix): If it's a dry base that must be mixed and frozen, or pasteurized before freezing — again, it's not RTE unless your facility provides a pasteurized liquid mix intended to be eaten without further kill steps.

Could Be Considered RTE If:

• You produce a dry powder that consumers might consume directly (e.g., protein shake mixes that are mixed with cold water/milk and consumed without heating).

• Or, if your labeling, branding, or usage instructions don’t clearly state a safety-related preparation step.

 Bottom Line:

• If your product requires the consumer to add hot water, cook, freeze, or otherwise apply a kill step, it's not considered RTE under FDA rules.

• But if your product is packaged and labeled in a way that encourages direct consumption without heating, then it may be treated as RTE — and would then require more stringent controls (e.g., environmental monitoring for Listeria, stricter hygiene, etc.).

 

Hope this will make sense

[Setanta]

Is your coffee sold dry or brewed? 

 

Ready-to-eat food (RTE food) means any food that is normally eaten in its raw state or any other food, including a processed food, for which it is reasonably foreseeable that the food will be eaten without further processing that would significantly minimize biological hazards.

[GMO]

From a wider (non legislative) viewpoint, foreseeable consumer misuse should be built into your HACCP or food safety plans.  Just have a quick google and work out if anyone is suggesting using your mushroom coffee in weird and wacky ways.

 

Yesterday I came across a wellness influencer aghast at the number of people suggesting normal coffee for, let's just say, an unusual application.  Consumer misuse is sadly rife nowadays.

[nwilson]

I think there is a slight difference in "ready to eat" and "ready for further processing, safe to consume".  Let take the ice cream mix as an example,  you could consume the mix and it should be completely safe, it is not ideal or customary to consume as is, however anyone could.  The mushroom coffee is another example and follows the same suit.  

 

By technical definition these would be ready to eat, there is just another application or process to make them more organoleptically viable from a consumer standpoint.  Still doesn't mean someone isn't going to take a dry mix and blend the heck out of it make some other concoction.  Keeping the ready to eat aspect will also drive folks to think that the material(s) should be handled in a manner that protects them from any further contamination.   Unless you have labeling that states some sort of cooking, pasteurization, or kill step otherwise, its ready to eat.  

[jfrey123]

Back when I worked in spices, we treated everything as RTE knowing most of our B2B transfers were going into other products that would be cooked.  This was because we knew some spices/blends were going straight to a facility for jarring for retail sale and some people sprinkle raw spices onto their plates of already cooked food.

 

Two the OP's two examples:

-The mushroom coffee is likely fine to consider NRTE, but your packages should include brewing instructions.  Some of the most shocking facilities I've seen in my short consulting career were tea makers, because most companies with a "to-be-brewed" product get away with some surprising practices simply because they're claiming the food-item gets steeped in boiling water and passed through a filter by the consumer.  Not saying OP is in this category, but just sharing an experience.

 

-The ice cream mix: is this like a powder a consumer mixes with milk and freezes to make ice cream?  Or is it a topping?  Either way, it should be treated as RTE by you and your team throughout all handling.  I'm going to assume it is created with RTE ingredients that are either processed to already be safe (say sugar) or inherently safe (say salt), and unless it is something the customer needs to cook, you need it to remain safe and RTE since the customer is going to mix it with RTE and consume it without a home kill-step.

 

I'm always a little wary when management wants to start using the NRTE defense in foods.  It's like they view NRTE as a hall pass to skimp on some of the PRP's and be a little loosy-goosy when managing risks.

[Bo16]

B2B RTE:  Ingredients to be used in other products, RTE or NRTE?  Would not be eaten with "as is", but meet FCC specifications for food.

FDA has other regulatory requirements for facility environments that manufacture RTE foods. 

 

So NRTE in its current form.  Issue arises when the 2nd business want to put the ingredient into a RTE food with out a kill step.

Example:  blend it with other ingredients and sell it for use, no kill step.  

 

I have seen many different definitions of RTE from our customers, some we meet, some we don't.

 

Thoughts?