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Can one product mix different HACCP categories in the same tray?

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verino98

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Posted 07 January 2026 - 11:32 AM

Hi All,

 

Is it possible to mix different HACCP categories (e.g. Not Heat Treated-Shelf Stable & Heat Treated - Shelf Stable) to have a single product?

 

I'll be more specific. My company wants to launch a new product (pre-sliced charcuterie duo) which will have two different meat products (flavors). One of those products has Fennel salami (Non Heat treated - Shelf stable) and Pepperoni (Heat Treated - Shelf Stable) in the same tray.

 

So, Is it possible to mix different HACCP categories (e.g. Not Heat Treated-Shelf Stable & Heat Treated - Shelf Stable) to have a single product?

 

Thank you all in advance!

 

 

 


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kfromNE

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Posted 07 January 2026 - 12:53 PM

Yes it is possible. I would ask your USDA inspector on how to do it. 


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verino98

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Posted 07 January 2026 - 01:35 PM

What HACCP category will then be the product under? 

How can be done the label approval? You must indicate the HACCP category


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GMO

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Posted 07 January 2026 - 01:37 PM

I've not worked in cured meats but know from other categories that while growth might be limited, especially before slicing, slicing machines themselves are notorious for Listeria harbourage.

Can someone explain to me why sliced charcuterie is ok unrefrigerated? There is one retailer in the UK who sells it this way (Lidl) but no other one does and I suspect the other retailers, who have technical teams (Lidl don't) would see it as too high a risk, not knowing how the consumer will then use it. While presence might be <10 cfu g-1 at point of sale, when assembled into a sandwich or salad, growth might occur due to changes in water activity with interfaces of other ingredients for example. By sale ambient it might also influence post consumer behaviour (for example storage of sandwiches at ambient by consumers isn't unusual.)

 

Sorry for the off topic ask.


Edited by GMO, 07 January 2026 - 01:38 PM.

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verino98

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Posted 07 January 2026 - 02:43 PM

It depends on what type of sliced charcuterie you are talking about and on which specific country regulation you refer bc every single country has its own.

 

Aged products can be generally also stored at ambiente temperature since water activity is below 0.92 but actually Staphylococcus aureus can grow below that value. Long story short: it is always best practice to store aged products refrigerated.

 

In Italy there is no restriction on temperature requirements for aged products.

There is a strict temperature requirement for cooked ham which is <4C.


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kfromNE

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Posted 07 January 2026 - 03:51 PM

I've not worked in cured meats but know from other categories that while growth might be limited, especially before slicing, slicing machines themselves are notorious for Listeria harbourage.

Can someone explain to me why sliced charcuterie is ok unrefrigerated? There is one retailer in the UK who sells it this way (Lidl) but no other one does and I suspect the other retailers, who have technical teams (Lidl don't) would see it as too high a risk, not knowing how the consumer will then use it. While presence might be <10 cfu g-1 at point of sale, when assembled into a sandwich or salad, growth might occur due to changes in water activity with interfaces of other ingredients for example. By sale ambient it might also influence post consumer behaviour (for example storage of sandwiches at ambient by consumers isn't unusual.)

 

Sorry for the off topic ask.

 

By way of being salt cured, acidified/fermented or dried. They are sub categories in the HACCP categories. 


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GMO

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Posted 07 January 2026 - 04:52 PM

By way of being salt cured, acidified/fermented or dried. They are sub categories in the HACCP categories. 

 

HACCP categories has no meaning outside of the US. There has still been incidents associated with sliced fermented cured meats with Listeria.

 

An example:

Some Tesco sliced chorizo is contaminated with listeria - how to spot affected packets


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kfromNE

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Posted 07 January 2026 - 07:51 PM

HACCP categories has no meaning outside of the US. There has still been incidents associated with sliced fermented cured meats with Listeria.

 

An example:

Some Tesco sliced chorizo is contaminated with listeria - how to spot affected packets

 

Never said it couldn't have listeria in it. If processes aren't followed correctly, it will happen. You asked how it was done to allow a product to be shelf stable. 

 

Attached are example of HACCP plans which show how the hazards are controlled. 

 

https://www.fsis.usd...lines/2021-0004

 

https://www.fsis.usd...lines/2025-0004

 

https://www.fsis.usd...D-2025-0004.pdf


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kfromNE

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Posted 07 January 2026 - 08:07 PM

Never said it couldn't have listeria in it. If processes aren't followed correctly, it will happen. You asked how it was done to allow a product to be shelf stable. 

 

Attached are example of HACCP plans which show how the hazards are controlled. 

 

https://www.fsis.usd...lines/2021-0004

 

https://www.fsis.usd...lines/2025-0004

 

https://www.fsis.usd...D-2025-0004.pdf

 

https://www.fsis.usd...and-food-safety

Below is found on the USDA website. 

Should people “At Risk” eat dry sausages?

Because dry sausages are not cooked, people “at risk” (older adults, very young children, pregnant women and those with immune systems weakened by disease or organ transplants) might want to avoid eating them. The bacterium E.scherichia coli (E. coli ) O157:H7 can survive the process of dry fermenting, and in 1994, some children became ill after eating dry cured salami containing the bacteria.

After the outbreak, FSIS developed specific processing rules for making dry sausages that must be followed or the product must be heat treated. These products are included in the FSIS microbial sampling program for E. coli O157:H7, and in 1997, FSIS began to test fermented sausages for Salmonella and Listeria monocytogenes.


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verino98

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Posted 07 January 2026 - 08:12 PM

Sorry to interrupt you guys but we are deviating from the original question ahahaha


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Scampi

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Posted 14 January 2026 - 05:36 PM

Are the packaging and storage the same for both items?


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Syzygy

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Posted 15 January 2026 - 08:16 AM

I don't see why not as both of them are shelf stable. There are lots of charcuterie products that contain different cold cuts and even sliced cheeses, which is another category. I think you just need to think of possible contamination if for example the heat treatment is not sufficient, then the other product will be affected too and vica versa. I would use the worst case scenario, which product has higher risk and treat the other one the same way as they are packed together.


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GMO

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Posted 15 January 2026 - 09:18 AM

I just really don't get why anyone would merchandise these on a shelf not in a chiller. 


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Scampi

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Posted 15 January 2026 - 02:06 PM

I just really don't get why anyone would merchandise these on a shelf not in a chiller. 

 Same reason meat sticks and beef jerky aren't    they don't need to be chilled


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GMO

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Posted 16 January 2026 - 07:56 AM

 Same reason meat sticks and beef jerky aren't    they don't need to be chilled

 

Meat sticks and beef jerky haven't been through a slicer post curing have they? Also the latter has a moisture absorption pack. It's similar to how I'd always refrigerate cut cheeses but maturing cheeses are often kept at c. 13oC.

I just don't see the benefit I guess. Especially as slicers are just implicated again and again in food poisoning incidents. One retailer does this in the UK with relatively high moisture activity hams. The others don't and wouldn't. The one who does it has no Technical staff on their retailer team (Lidl). I don't think that's a coincidence.


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GMO

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Posted 16 January 2026 - 12:57 PM

But apologies for going  :off_topic:


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