Microbiological limits for RTE product - raw sunflower kernels

Hello,

I would need your assistance about defining the maximum acceptable limit for yeast and mold in the product raw sunflower kernels.

Accoriding to the the product specification of manufactorers the limit is 10 000 cfu.

In EU regulations 2073/2005 latest version 2020, there is no limid about this or similar product.

With the new regulation 2023/915, there is also noting mentiond about the yease and mold.

Can you help me with definng is 10 000 cfu too much, or it is acceptable maximum limid?

Thank you

Are you exceeding 10,000 cfu/gm? Do you test for aflatoxin? 

We test each lot of the produced product. 

Тhe highest value you ever got after a test in laboratory for yeast / mold, was between 3000-4000 cfu/mg.

We also test aflatoxin, the result is always <0.60 mg/kg.

Regulation (EC) No 2073/2005 on microbiological criteria for foodstuffs, does not provide explicit limits for yeast and mold in sunflower kernels or similar products.

The new Regulation (EU) 2023/915, which deals with various food contaminants, also does not set specific limits for yeast and mold in sunflower kernels.

In the product specification we have set for yeast / mold 10 000 cfu/mg as the maximum allowable value, but how to know if this is correct if there is no specific regulations for this.

Is this RTE? 

The product is edible – For general consumer consumption, predominantly as an ingredient.