Codex CXC 58-2005, the Code of Hygienic Practice for Meat adopted in 2005, is the international reference for minced meat, burger and meat products plants. Its section 9.7 lists what to control when meat is minced, mechanically separated or made into preparations, and leaves the time and temperature limits to each competent authority, such as Dubai Municipality or the EU.
This guide is for production managers, HACCP teams and inspectors in plants making minced meat, burger patties, kofta, nuggets and cooked meat products.
Why is minced meat a higher risk than a whole cut?
On a whole cut, bacteria sit mostly on the outside, and cooking reaches the surface first. Mincing spreads that surface contamination through the whole batch, including the centre of a patty that a quick sear will not heat. One contaminated piece of trim can end up in hundreds of packs from the same grinding lot.
Codex treats these products as their own categories. In CXC 58-2005, minced meat is boneless meat reduced to fragments. A meat preparation is raw meat with foodstuffs, seasonings or additives added, which covers most seasoned burgers and kofta. Mechanically separated meat (MSM) is meat removed from bones by machine in a way that breaks down the muscle fibre structure.
Shiga toxin-producing E. coli (STEC) is a recognised hazard in raw beef. Codex adopted separate guidelines that cover STEC control in raw beef and other foods, CXG 99-2023, in November 2023, as Codex itself reported in 2024. Control starts at slaughter, which our guide on slaughterhouse hygiene covers.
What does Codex CXC 58-2005 require when meat is minced?
Section 9.7 sets out the controls in plain terms. Summarised in our own words, they are:
- Raw material for mincing comes only from parts the competent authority allows, such as skeletal muscle with its attached fat. It must contain no bone fragments or skin. Abnormal tissue and any contamination picked up after dressing are trimmed off before mincing.
- The competent authority may set compositional criteria for minced meat. For MSM, it should restrict which animal parts are used, set a maximum calcium content and require specific labelling.
- The authority can set maximum times and temperatures for each step, from chilling or freezing of the raw material to preparation and final chilling.
- Product not used straight away as an ingredient is wrapped or packed and refrigerated at once. Thawed material is not refrozen.
- Lines handling minced or mechanically separated meat have in-line magnets or another way of detecting metal.
- Rooms for cutting, mincing, mechanical separation and further processing are laid out so that the work does not cross-contaminate.
Paragraph 153 adds that the plant must set and validate the shelf life of its meat preparations and manufactured products. Annex II describes microbiological testing to verify that process control is working.
Which limits apply in Dubai and in the EU?
Because Codex sets principles rather than figures, the limits on your HACCP plan depend on where you produce and sell. The table compares Codex with two authorities whose texts we checked. Always say whose limit a figure is.
| Control point | Codex CXC 58-2005 | Dubai Municipality Food Code 2013 | EU Regulation (EC) No 853/2004, Annex III Section V |
|---|---|---|---|
| Meat entering the preparation room | Bring in progressively, keep the cold chain | Chilled high-risk food at 5 °C or below (3.6.2) | Not above 7 °C for red meat, 4 °C for poultry, 3 °C for offal |
| Age of chilled raw material for mincing | Time limits left to the competent authority | No specific limit found | Within 6 days of slaughter for red meat, 3 days for poultry, 15 days for boned vacuum-packed beef and veal |
| Minced meat after production | Wrap and refrigerate immediately | 5 °C or below, or frozen at -18 °C (3.6.2) | Internal temperature not above 2 °C, or -18 °C frozen |
| Meat preparations after production | Process criteria set by the authority | 5 °C or below, or frozen at -18 °C (3.6.2) | Internal temperature not above 4 °C, or -18 °C frozen |
| Thawing | No refreezing after thawing | Product not above 5 °C, cook within 72 hours of the start of thawing, refreezing only with prior approval (3.2.7) | Frozen meat for mincing must have been boned before freezing, unless the authority allows boning just before mincing |
| Cooking | Validated time and internal temperature | Core at least 75 °C or an equivalent time and temperature, checked with a calibrated thermometer (3.2.8) | No cooking temperature set in this section |
The Dubai Food Code applies to every food establishment in the emirate, manufacturers included (1.4). Other emirates and GCC countries publish their own rules, so check your authority's current text before you set critical limits.
What changes on a burger line?
A burger plant adds three controls that a general meat products plant may not need.
First, define the grinding lot. A practical definition is the meat that passes through the grinder between two full cleans, and its size decides how much product a single positive test affects. Record the lot on every pack and keep the raw material batches that went into it.
Second, control the raw material bought for grinding. Specify the trim's fat class, temperature on arrival and microbiological limits in the supplier contract, and test against them. CXG 99-2023 sets out STEC control measures for raw beef that you can build into supplier approval.
Third, treat the cooking instructions as a control measure. A raw patty is made safe in the customer's kitchen, so the instructions on the label are part of your food safety controls and should reach a safe core temperature. In Dubai, the Food Code's 75 °C core temperature is the figure food businesses cook to. Validate your instructions on the thickest patty you make, from frozen if that is how it is sold.
Frozen patties also depend on the cold chain. The Dubai Food Code says raw frozen food must not exceed -10 °C while it is received or transferred (3.6.3).
How do kofta, nuggets and cooked products differ?
Kofta, sausages and seasoned mixes are meat preparations. Spices and other non-meat ingredients come under good hygienic practice and HACCP, and CXC 58-2005 notes that herbs and spices may need a decontamination treatment. Products containing non-meat protein should be labelled accordingly.
Coated and cooked products such as nuggets add a kill step and a ready-to-eat area. The cooking step needs a validated time and internal temperature. After cooking, Codex expects sanitation procedures and routine microbiological verification to keep Listeria monocytogenes out, and raw product must not cross paths with ready-to-eat product.
Cured, smoked and emulsified products bring their own process criteria, which our guide to processed meat production covers.
What records will an inspector ask to see?
The records below are our interpretation of what proves each control. Your authority may ask for more.
- Receiving records: temperature, supplier, slaughter or production date and lot of every raw material delivery.
- Room and product temperatures in the mincing and forming areas, with the time product spends out of chill.
- Grinding lot records that link each finished lot to its raw material batches, plus cleaning records between lots.
- Metal detector or magnet checks at the frequency in your HACCP plan, with action taken on failures.
- Cooking logs with core temperatures, the thermometer used and its calibration.
- Thawing logs, shelf-life validation studies and microbiological verification results against your criteria.
These records sit inside a HACCP system built on the Codex general principles. Our guide to Codex HACCP explains how the hazard analysis and critical limits fit together.
How AGS can help
AGS offers two single-document guidelines for these plants, each one editable Microsoft Word file:
- Technical & Hygiene Guidelines - Meat Products Manufacturing: 1 document, a technical and hygiene guideline for meat products manufacturing.
- Technical & Hygiene Guidelines - Burger Manufacturing Plants: 1 document, a technical and hygiene guideline for burger manufacturing plants.
Frequently asked questions
Is Codex CXC 58-2005 still current?
Yes. It was adopted in 2005 and replaced several older Codex codes for fresh meat, game and processed meat. It refers to the 2003 revision of the General Principles of Food Hygiene, which Codex has since revised again, so use the current general principles alongside it.
Does Codex set a storage temperature for minced meat?
No. It requires immediate wrapping and refrigeration and leaves the figures to the competent authority. That is why the EU sets 2 °C and the Dubai Food Code works with 5 °C.
Is a seasoned burger patty minced meat or a meat preparation?
Under the Codex definitions, raw meat with seasonings or additives added is a meat preparation. A patty of plain minced beef is minced meat. The difference matters where an authority sets different limits for each, as the EU does.
Can thawed meat be refrozen in Dubai?
Only for specific processes with prior approval from Dubai Municipality's food control department, and only if it was thawed at no more than 5 °C.
AGS provides independent documentation toolkits. This guide refers to Codex Alimentarius texts, the Dubai Municipality Food Code and EU legislation for identification only. AGS is not affiliated with, endorsed by or approved by the Codex Alimentarius Commission, Dubai Municipality, the European Commission or any certification body, and following this guide does not guarantee any inspection or audit outcome.
Reviewed October 2026. Facts checked against the sources current at publication.
