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Bulk freezing of ambient and chilled foods

Guidance for businesses on bulk freezing food products originally intended to be supplied and sold as ambient or chilled products.

Last updated: 31 January 2024
Last updated: 31 January 2024

This guidance is for food businesses who wish to freeze food which was originally intended to be supplied and sold as ambient or chilled products.

This guidance focuses on food safety and provides the main legislative requirements that must be met when freezing food. It is intended to outline general provisions that can be applied to individual circumstances.

It is not possible to provide definitive advice for all circumstances on whether the freezing and refreezing of ambient and chilled food products can be undertaken. Equally, it is not possible to define how such products should be handled or processed when they are brought out of cold storage. This is because of the very wide range of products, industry practices and specific safety and hygiene requirements that could apply.

You will need to consider the type of food to be frozen. ‘Ready to Eat’ foods which are designed to be consumed without a further processing step which would reduce risks from pathogens will require different considerations from those foods designed to be cooked following defrosting.

Bulk freezing food

Freezing or refreezing of an ambient or chilled food product, including surplus food, is generally permitted. This is subject to the hygiene conditions set down in assimilated Regulation (EC) 852/2004 and, if relevant, assimilated Regulation (EC) 853/2004. Exceptions are described in the legislative requirements section.

You must carry out freezing of the food safely and maintain cold temperatures. It is unlikely that this would lead to microbiological safety issues if commercial defrosting, processing and refreezing are carried out in a controlled way. This requires application of time and temperature combinations that prevent the growth of pathogens and hygienic conditions.

If your business, trade body, or group of businesses has an existing Primary Authority partnership in place for food, you should consider seeking specific advice from them.

If your business does not have a Primary Authority partnership for food, it may be necessary for you to discuss your specific situation with your local food authority and/or Official Veterinarian (OV) as appropriate. 

This will have significant relevance in determining handling and further processing of the product, particularly where the intended use is being altered.

Labelling changes

You should ensure food products comply fully with the legislative requirements for labelling and traceability having regard to the intended use of the food. These remain intrinsic to ensuring food safety and protecting consumers.

You must label any ambient or chilled foods which are to be frozen with: 

  • date of freezing where this is required by legislation, for example for meat, meat preparations and unprocessed fishery products 
  • date of minimum durability (best before date)
  • details of Food Business Operator (FBO) undertaking freezing. You should replace the details of the business that originally produced the food given on the pack with your own, where necessary, to reflect this change. You are then responsible for the information on the label 
  • conditions for safe storage, defrosting and use. You should provide appropriate instructions for safe storage and use, including de-frosting and cooking. 
  • amended name of food product. You should include an indication in the product name that it is frozen if it was originally intended to be placed on the market as an ambient or chilled product. Include this where omission of this information could mislead the consumer.

When you amend the product labelling, you must take care to fully obscure or delete the original information that is no longer accurate. Failure to do this may lead to the incorrect preparation of the food.

Traceability records

Your traceability records should detail each batch of food for which the [durability date] has been modified. This should include:

  • batch
  • former and new durability date
  • date the change was made
  • reason for the change
  • evidence. You must be able to provide appropriate evidence to show how the new durability date mark has been validated as safe. This should be part of your Food Safety Management System (FSMS) based on a Hazard Analysis and Critical Control Point (HACCP) study. If you did not produce the food yourself, you should consult the manufacturer of the product. They will hold information on shelf life and packaging characteristics which will help to establish the new date

Freezing requirements

You must make sure that cold store freezers can reduce chilled foods to the required core temperature within an appropriate timeframe. For example, to -18°C. This is to limit any microbiological growth in the food product, and to ensure food safety.

Foods bearing a ‘use by’ date must be ‘frozen’ before the expiration of their durability date. For ‘use-by’ dates the latest point would be midnight on the date indicated, 

You must validate, verify and monitor temperatures throughout the period of freezing to ensure appropriate storage temperatures are maintained. 

You will also need to assess the suitability of foods and packaging for freezing. You will need to determine whether food will need to be removed from pallets or other storage arrangements, in order to facilitate safe and appropriate freezing.

Legislative requirements

Food placed on the market should be safe. Traceability for food at all stages of production, processing and distribution should be clearly established. This is in line with assimilated Regulation (EC) No 178/2002.

Food businesses are required to implement a food safety management system based on HACCP principles and good hygienic practice; and to maintain the integrity of the cold chain. This is in line with assimilated Regulation (EC) No 852/2004.

Requirements relating to the storage of products of animal origin when frozen are legislated in assimilated Regulation (EC) No 853/2004. This includes requirements that:

  • In approved establishments meat can be frozen subject to meeting the hygiene requirements of assimilated Regulation (EC) 853/2004, including the requirements for certain information for frozen food of animal origin in Section IV, Annex II; for freezing and storage of fresh meat in Sections I to IV, Annex III and for minced meat, meat preparations and mechanically separated meat (MSM) in Section V, Annex III.  Fresh meat intended for freezing must be frozen without undue delay. 
  • Minced meat, meat preparations and MSM can be frozen but not re-frozen after thawing.
  • Before the point at which the retail label is applied to frozen foods of animal origin, you need to make information available to the business to whom the food is supplied and the relevant competent authority in relation to the date of production and date of freezing where different from the date of production.

Food businesses must provide relevant information including the durability, storage and safe use of the food. This is in line with assimilated Regulation (EU) No 1169/2011. This includes requirements that:

  • After the ‘use-by’ date a food is considered to be unsafe in accordance with Article 14(2) to (5) of assimilated Regulation (EC) 178/2002.
  • Food with an expired ‘use-by’ date must not be sold, supplied or stored for sale. This Regulation provides flexibility to allow food businesses to change a durability marking, but only where the modification does not mislead the final consumer, reduce the level of consumer protection, or restrict the final consumer from making an informed choice.
  • You must not make a change in isolation without appropriate validation to show that extending the ‘use-by’ date will not increase the risk to the consumer.