Hi miniac ,
As I understand yr product (post 5) is "pastries with the cream or custard" (="XYZ"). (Unknown as to whether all baked together or cream added later).
From FDA website -
Definitions:
Frozen desserts—Ice cream, frozen custard, French ice cream, French custard ice cream, frozen dietary dairy dessert, frozen yogurt, dietary frozen dessert or low fat frozen dairy dessert, ice
milk, freezer-made milk shakes, fruit sherbet, water ices, quiescently frozen confections, quiescently frozen dairy confections, whipped cream confections, bisque tortoni, mellorine
frozen desserts, and products which are similar in appearance, odor or taste to the products or are prepared or frozen as such products are customarily prepared or frozen, whether made
with dairy or nondairy products.
The term does not include commonly known or designated bakery products as frozen cakes and pastries, cream pies and fillings and toppings, meringue
pie fillings and toppings, cream and ice box pies, fruit and custard pie fillings, Boston cream pie fillings, cream puff fillings and custards, eclair and Napoleon fillings, and custards or similar
products.
FDA - Frozen Dessert Testing Fact Sheet.pdf 403.54KB
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I deduce XYZ is not a "Frozen dessert (FD)" ?
The micro. requirement for FD is given as -
Test Standards:
Standard Plate Count, or SPC, shall not exceed 50,000 cfu/gm (cultured product is exempt)
Coliform Group Count shall not exceed 10 cfu/gm except in product to which fruit, nuts or
bulky flavor is added after pasteurization when the count may not exceed 20 cfu/gm
However It appears there is no official FDA Standard for your product, "XYZ".
The debate over appropriate Coliform levels for XYZ seems to have a long history.
You can indeed find historical support for a coliform (rejection) limit of 10,000 cfu/gram, eg ICMSF,1982)/IFST,1997 (attached, cfp1,cfp2) but I anticipate such proposals for currently discussed products are obsolete. (the limit is also discussed in attachment cfp4).
cfp1 - sampling-testing of foods, ICMSF,Clark,1982.pdf 510.8KB
12 downloads
cfp2 - micro.criteria for foods,IFST,1997,Stannard.pdf 2.59MB
14 downloads
The most comprehensive review of US commercial cream filled pastries I could find (which included coliform data) is also old (1976)(attached, cfp3) and supported the (much lower) proposed limit (50cfu/gram) in my post 6.
cfp3 - Cream filled pastries, USA,,Bryan,1976.pdf 823.87KB
12 downloads
This limit afaik was never generally implemented probably for reasons such as noted in this later Canadian review (1983)(attached,cfp4) -
The m values [50,000/50] for ACC and coliforms are based on the microbial limits proposed by the Food and Drug Administration (1,12), that were later withdrawn because of industry pressure (2,3,4), but are consistent with desirable manufacturing practices.
cfp4 - cream-type pies, Canada,Todd,1982.pdf 386.85KB
13 downloads
It's not my Product area but the "general" impression I get is that the coliform level should, maximally, be <100 cfu/gram for cream filled items as being discussed. This is a GMP "limit".
So I suggest you exercise caution over increasing any limit over 1000 cfu/gram which already looks to be on the high end.
PS - above was posted before I saw Ryan's Post.
To be, or not to be, a Frozen Dessert. That is the Question. 
