The FDA Food Code is a model set of food safety regulations that most US states adopt (in full or with modifications) as the basis for their own food codes. It covers temperature control, employee health, food handling, equipment standards, and HACCP requirements. Understanding the FDA Food Code is essential because your state's rules are built on it, and the critical limits in your HACCP plan come directly from its standards.
For how these requirements fit into a complete food safety program, see our food safety compliance guide. For building a HACCP plan based on these requirements, see what a HACCP plan is.
What the FDA Food Code is
The FDA Food Code is a model code, not a federal law. The FDA publishes it approximately every four years as a set of recommended regulations for retail food establishments (restaurants, food trucks, cloud kitchens, caterers, grocery stores, and other businesses that sell food directly to consumers). The most recent version is the 2022 Food Code.
The FDA does not enforce the Food Code directly. It does not inspect food trucks or restaurants. Instead, state and local health departments adopt the Food Code (in whole or with state-specific modifications) as the basis for their own food safety regulations and enforce those regulations through permitting and inspections.
Most states have adopted some version of the FDA Food Code. Some adopt the current version promptly. Others may still be operating under an older version. The FDA tracks which version each state has adopted through its Retail Food Protection Cooperative Programs.
For small food business operators, the practical implication is that the FDA Food Code is the starting point for understanding your state's food safety requirements. Most of the critical limits, employee health requirements, and food handling standards in your state's food code originated in the FDA Food Code.
Key temperature requirements from the FDA Food Code
Temperature control is the most critical aspect of the FDA Food Code for small food businesses. These are the numbers that define safe vs unsafe in your HACCP plan.
Cooking temperatures
The FDA Food Code specifies minimum internal cooking temperatures for different food types. These temperatures are designed to kill pathogenic bacteria to safe levels.
| Food Type | Minimum Internal Temperature | Hold Time | |-----------|------------------------------|-----------| | Poultry (chicken, turkey, duck) | 165°F | 15 seconds | | Stuffed meat, pasta, and stuffing | 165°F | 15 seconds | | Ground meat (beef, pork, lamb) | 155°F | 15 seconds | | Injected or mechanically tenderized meat | 155°F | 15 seconds | | Whole cuts of beef, pork, lamb, veal | 145°F | 15 seconds | | Fish and seafood | 145°F | 15 seconds | | Eggs for immediate service | 145°F | 15 seconds | | Commercially processed, ready-to-eat food (reheating) | 135°F | No minimum | | Fruits, vegetables, grains, legumes (hot holding) | 135°F | No minimum |
These temperatures represent the minimum at which food is considered safe. There is no maximum, though overcooking affects food quality (not safety).
Cold holding
All potentially hazardous foods (also called TCS foods, for Time/Temperature Control for Safety) must be held at 41°F or below when in cold storage or cold holding during service. This includes raw proteins, dairy products, cut fruits and vegetables, cooked grains, and any food that supports bacterial growth.
Hot holding
Cooked food held for service (on a steam table, in a warming drawer, under a heat lamp) must be maintained at 135°F or above. Food that drops below 135°F enters the temperature danger zone and must be reheated to 165°F within 2 hours or discarded.
The temperature danger zone
The temperature danger zone is 41°F to 135°F. Within this range, bacteria can double in number every 20 minutes. The FDA Food Code limits the cumulative time food can spend in the danger zone to 4 hours. After 4 hours, the food must be discarded.
Some food businesses use "time as a public health control" to hold food without temperature control for up to 4 hours. This requires written procedures, time-marking on each item, and strict discard protocols.
Cooling requirements
Cooked food that will be stored (not served immediately) must be cooled in two stages:
- Stage 1: From 135°F to 70°F within 2 hours
- Stage 2: From 70°F to 41°F within an additional 4 hours
Total cooling time: 6 hours maximum. The reason for the two-stage requirement is that bacteria grow fastest between 125°F and 70°F, so the food must pass through this range quickly.
Cooling methods include shallow pans, ice baths, blast chillers, and stirring. Dense foods (soups, stews, rice) cool slowly and may need active intervention.
Reheating
Food that has been cooked, cooled, and is being reheated for hot holding must reach 165°F within 2 hours. This is stricter than the original cooking temperature for some foods (whole cuts of meat only need 145°F when cooked initially but must reach 165°F when reheated).
For a practical guide to temperature monitoring, see our temperature log guide.
Employee health and hygiene requirements
The FDA Food Code includes detailed requirements for employee health and personal hygiene.
Handwashing
Employees must wash their hands with soap and warm running water for at least 20 seconds, including under fingernails and between fingers. Hands must be dried with single-use paper towels or a hand dryer.
Handwashing is required: before starting food preparation, after handling raw meat or poultry, after using the restroom, after touching the face, hair, or body, after sneezing or coughing, after handling garbage, after handling money, after cleaning activities, and after any interruption in food preparation.
Employee illness exclusions
The Food Code requires food employees to report certain health conditions to the person in charge. Employees must be excluded from working with food if they have been diagnosed with Salmonella Typhi, Shigella, E. coli O157:H7 or other STEC, Hepatitis A virus, or Norovirus.
Employees with symptoms of vomiting, diarrhea, jaundice, or sore throat with fever must be restricted from food handling duties until the symptoms resolve.
No bare-hand contact with ready-to-eat food
Food employees may not contact ready-to-eat food with bare hands. Gloves, tongs, spatulas, deli tissue, or other utensils must be used. Ready-to-eat food includes any food that will not be cooked or reheated before serving: salads, bread, garnishes, cut fruit, and cooked foods ready for service.
Hair restraints and clean garments
Food employees must wear effective hair restraints (hats, hairnets, or other coverings) and clean outer garments. These requirements prevent physical contamination of food.
Food handling and storage requirements
The FDA Food Code establishes specific rules for how food is handled and stored throughout the operation.
Cross-contamination prevention
Raw animal proteins must be stored separately from ready-to-eat foods. In shared refrigerators, the storage order from top to bottom should be: ready-to-eat foods, whole fish and whole cuts of beef and pork, ground meat, and poultry on the bottom shelf. This order is based on the cooking temperatures required for each food type (poultry requires the highest temperature and therefore poses the greatest risk if it contaminates other foods).
Cutting boards, utensils, and prep surfaces used for raw meat must be washed, rinsed, and sanitized before being used for ready-to-eat food.
Date marking
Ready-to-eat TCS food that is prepared on-site and held for more than 24 hours must be date-marked with the day of preparation and the day by which it must be consumed or discarded. The maximum holding time at 41°F is 7 days (counting the day of preparation as day 1).
Allergen awareness
The Food Code requires food employees to be informed about the major food allergens and trained to prevent allergen cross-contact. The nine major allergens recognized by the FDA are milk, eggs, fish, crustacean shellfish, tree nuts, peanuts, wheat, soybeans, and sesame.
FIFO (First In, First Out)
While not explicitly mandated by the Food Code as a regulation, FIFO is a recommended best practice for inventory management. Older product should be used before newer product to prevent food from expiring in storage.
Equipment and facility requirements
The FDA Food Code establishes standards for the physical environment where food is prepared and served.
Food contact surfaces must be smooth, easily cleanable, durable, and non-absorbent. Materials like stainless steel, food-grade plastic, and tempered glass meet these requirements. Wood (except for cutting boards made of hardwood) and porous materials do not.
Adequate ventilation is required over cooking equipment to remove grease, smoke, steam, and heat. Commercial kitchen hoods with filters are the standard solution.
Adequate lighting is required in food preparation areas. The Food Code specifies 50 foot-candles at surfaces where food is prepared, processed, or examined, and 20 foot-candles in other food preparation areas.
Handwash sinks must be provided in food preparation areas and must be accessible (not blocked by equipment or supplies), supplied with warm running water, soap, and single-use towels.
Pest control measures must be in place to prevent the entry of insects, rodents, and other pests.
HACCP and the FDA Food Code
The FDA Food Code takes a nuanced approach to HACCP for retail food businesses.
Specialized processes require HACCP plans. The Food Code mandates formal HACCP plans for operations conducting specialized processes: reduced oxygen packaging (sous vide, vacuum sealing), smoking and curing for preservation, using food additives for preservation, sprouting seeds or beans, and custom processing that is not addressed by standard Food Code provisions.
Standard operations require active managerial control. For standard retail food operations (cooking, holding, serving), the Food Code requires "active managerial control" of foodborne illness risk factors rather than a formal HACCP plan. In practice, demonstrating active managerial control means having procedures, monitoring, and documentation that follow the same HACCP principles.
Most health departments interpret this to mean that a HACCP plan (or equivalent food safety plan) is effectively required for all food establishments. For food truck operators and cloud kitchen owners, the practical advice is the same: build a HACCP plan and follow it daily. For step-by-step guidance, see our guide on how to create a HACCP plan.
How your state adopts the FDA Food Code
Each state decides whether and how to adopt the FDA Food Code. The adoption process varies.
Full adoption. Some states adopt the FDA Food Code in its entirety, with minimal modifications. These states' food codes closely mirror the federal model.
Modified adoption. Many states adopt the FDA Food Code as a baseline but add state-specific modifications. These may include stricter requirements (lower cold holding temperatures, additional training mandates), additional permit categories, state-specific mobile food vendor regulations, or modified enforcement procedures.
Delayed adoption. Some states may still be operating under an older version of the FDA Food Code. A state that adopted the 2017 Food Code may not yet have incorporated changes from the 2022 version.
For Texas, the Department of State Health Services has adopted the FDA Food Code with state-specific rules for mobile food units and temporary food establishments. For California, the California Retail Food Code is based on FDA Food Code principles but includes additional California-specific requirements.
The key takeaway: always verify your state's specific food code rather than relying solely on the FDA Food Code. PassMyKitchen tracks state-specific variations for all 50 states and adjusts your HACCP plan accordingly. For state-by-state details, see our state compliance pages.
Simplify your compliance with PassMyKitchen
The FDA Food Code sets the standards. Your state enforces them. PassMyKitchen helps you meet them. Generate a HACCP plan that incorporates your state's specific food code requirements, log your daily monitoring with automatic timestamps, and present everything to inspectors in one tap.
Start your free trial and get a HACCP plan built on FDA Food Code standards in 30 seconds.
Frequently asked questions
Is the FDA Food Code a law?
No. The FDA Food Code is a model code, a set of recommended regulations that the FDA publishes for states to adopt voluntarily. It is not directly enforceable as a federal law. However, when your state adopts the Food Code (in whole or with modifications), the adopted version becomes part of your state's law and is enforceable by your state and local health departments. In practical terms, the FDA Food Code has the force of law in your state because your state has made it law.
How often does the FDA Food Code change?
The FDA publishes a new edition of the Food Code approximately every four years. The most recent edition is the 2022 Food Code. Between full editions, the FDA may issue supplements with interim changes. When a new edition is published, states decide whether and when to adopt it. Some states adopt new editions quickly; others may take several years.
Which version of the FDA Food Code does my state use?
The FDA publishes a list of which Food Code version each state has adopted through its Retail Food Protection Cooperative Programs page. You can also check directly with your state health department. PassMyKitchen tracks the current adoption status for all 50 states and adjusts your HACCP plan to match.
Does the FDA inspect food trucks?
No. The FDA does not inspect retail food establishments (restaurants, food trucks, cloud kitchens, caterers). Inspections are conducted by your state or local health department. The FDA's role is to publish the model Food Code and support state adoption. The actual enforcement, permitting, and inspection of food trucks is handled entirely at the state and local level. For details on food truck inspections, see our guide on food truck health inspections.