Cold smoking fish and meat in hospitality

Is it still permitted under the new 2027 Hospitality Hygiene Code?

What exactly is changing?

11/12/2026

The new Hospitality Hygiene Code, effective from November 2026, introduces revised requirements for cold smoking fish. Previously, hospitality businesses could generally rely on the standard protocols provided in the code. Under the new code, cold smoking fish is no longer classified as an inherently safe standard preparation method. This does not mean the practice is banned, but rather that operators must independently demonstrate and substantiate its safety.

Henk Groenendijk, Food Safety Expert at Eurofins Bureau de Wit, explains: "Hot smoked salmon remains fully permitted, but cold smoking is no longer considered a standard safe process."

Hot smoking vs. cold smoking: What does this mean for your kitchen?

Hot smoking: During smoking, fish and meat are heated to over 65 °C for at least 10 minutes and is fully cooked through. Typical examples include hot smoked salmon or mackerel. The heat eliminates most pathogens, making this a relatively safe preparation method.
Cold smoking: Fish and meat are not cooked; temperatures remain below 30 °C. The product is first cured with salt (dry-cured or brined) and subsequently smoked and dried. While salt, smoke, and dehydration provide flavour and a preservative effect, the fish essentially remains raw. Cold smoked salmon is a classic example. Because there is no heat kill-step, pathogens such as Listeria can survive. Consequently, safety depends entirely on precise process control: salt concentration, temperature control, smoking duration, and subsequent cold storage conditions.

What does ‘operating outside the hygiene code’ mean?

The new Hospitality Hygiene Code accommodates operators who implement non-standard culinary methods. "You are allowed to operate outside the standard hygiene code," Henk notes, "provided you comprehensively validate the process through systematic monitoring and laboratory sampling."

In practice, this requires two key actions:

Monitoring: Documenting, tracking, and verifying critical process steps.
Laboratory sampling: Submitting finished products for microbiological analysis to provide objective proof that the end product is safe for consumption.

Who is impacted?

The regulatory change does not affect all businesses equally. For operators specialising in house-cured, cold smoked fish, the method remains viable, provided it is supported by thorough documentation and testing. For kitchens that only do this occasionally, the threshold is significantly higher. Henk points out: "Cold smoking raw salmon on an ad-hoc basis as a novelty, without a fully validated and documented process, will no longer be permitted."

Are the rules becoming universally stricter?

Henk observes that many operators assume the updated Hospitality Hygiene Code merely introduces tighter restrictions, but he emphasises that this perception is inaccurate: "Certain areas are indeed subject to stricter controls, such as cold smoking fish. However, other sections have been revised to better reflect realistic hospitality kitchen workflows."

Stricter requirements in the new Hospitality Hygiene Code:

Cold smoking fish is no longer considered a standard safe preparation method and requires technical validation.
Handwashing after handling raw eggs is explicitly mandated and requires verifiable compliance.
Kitchen machinery and equipment must carry the CE marking.
Glasswasher final rinse cycles must reach a specified water temperature of 60 °C.
Businesses must demonstrably conduct periodic food safety briefings, provide verifiable staff training, and record corrective actions for deviations.

More practical or flexible updates in the new Hospitality Hygiene Code:

Food delivery: Orders fulfilled by in-house delivery services within 30 minutes no longer require time-logging records. If delivery exceeds 30 minutes, time tracking remains mandatory.
Batter and soft dough: May now be held ambiently outside cold storage for up to two hours, compared to the previous one-hour limit. This applies to products such as pancakes, mini pancakes, waffles, tempura, beer batter, churros, etc.
Prepped raw vegetables: Cut vegetables intended for cooking (such as diced onions or chopped broccoli) may temporarily sit at prep stations without refrigeration. Cut vegetables served cold or raw must remain refrigerated at all times.
Vending machines and hot-holding displays: Prepared burgers in hot-display cases no longer need to remain continuously above 60 °C, provided they are thoroughly cooked through and held for no longer than 30 minutes.
Fermentation: The fermentation of vegetables is now formally recognised and incorporated into the Hospitality Hygiene Code.

Henk emphasises that the guiding principle behind the changes is food safety awareness: "Food safety should not be reduced to merely checking boxes on a list. It ultimately comes down to understanding the actual microbiological risks and managing them correctly during daily kitchen operations. The new code is designed to align more closely with modern culinary practices. As the hospitality industry continues to innovate, the hygiene code must evolve alongside it."

Recommended action steps:

Identify cold smoking practices: Determine whether your kitchen prepares cold smoked fish and meat, including seasonal specials or occasional events.
Evaluate frequency and intent: Assess whether cold smoking is a core offering worth maintaining or an occasional experiment.
Validate your workflow: If you intend to continue, formalise standard operating procedures (SOPs) and establish continuous monitoring protocols.
Schedule laboratory sampling: Arrange microbiological testing to build verification records confirming product safety.
Train your team: Ensure kitchen staff are properly instructed on the revised standards, with written records of completed training.

Need assistance preparing your kitchen?

If you want to continue cold smoking fish and meat, and need guidance establishing scientific validation, at Eurofins Bureau de Wit, our team can assist with process validation, environmental monitoring, and laboratory sampling. For additional information on the new guidelines, consult our primary article on the 2026 Hospitality Hygiene Code or register for our interactive classroom courses and e-learning programs.

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