HACCP Date Coding & Stock Rotation Explained: The Complete UK Guide (2026)
Date coding and stock rotation are the parts of your HACCP plan an EHO can check in ninety seconds — open a fridge, read the labels, and see whether the system is real or theatre. There are two legally distinct dates: use-by is a safety date and it is a criminal offence to sell food past it; best-before is a quality date and legally sellable afterwards. On top of the manufacturer’s date sits your own: a day-dot or date label giving opened or prepared food its own shelf life — commonly the “use within 2 days” rule for high-risk items. Rotate on FIFO (first in, first out) for ambient stock and FEFO (first expiry, first out) for anything dated, label defrosted stock with its own use-by, and keep the records that prove it. This guide covers each of those in the order they trip kitchens up.
- Use-by = safety, best-before = quality: under UK food law it is an offence to sell or serve food after its use-by date. Best-before is about peak quality and food remains legal to sell and eat afterwards, provided it is otherwise fit. Never treat the two as interchangeable.
- Don’t remove or overwrite a use-by date: altering or obscuring a supplier’s use-by date is unlawful. Your own day-dot supplements it — it never replaces it.
- Opened shelf life: once a use-by product is opened, the supplier’s date may no longer hold. Many UK kitchens apply a 2-day rule (day of opening/prep = day 1, use by end of day 2) for high-risk ready-to-eat foods, unless the manufacturer or your validated HACCP plan states otherwise.
- FIFO vs FEFO: use FIFO (first in, first out) for undated ambient goods and FEFO (first expiry, first out) for anything carrying a date — because the oldest delivery is not always the soonest to expire.
- The law behind it: retained Regulation (EC) 852/2004 requires a permanent HACCP-based food safety management system; stock rotation and date control are core prerequisite controls within it.
- Temperature underpins dates: a use-by date assumes correct storage. High-risk chilled food must be held at 8°C or below under the Food Safety (Temperature Control) Regulations 1995 — a date is only valid if the cold chain held.
- Defrosted food gets a new date: once frozen food is defrosted for use, the frozen date is spent. Label it with a fresh use-by (typically 24 hours, chilled) and never refreeze raw defrosted product.
- Records: a labelling system with no written procedure and no rotation check log looks unmanaged to an inspector. Keep the label key, the opened-shelf-life chart and a simple date-check record — if it is not written down, the assumption is it did not happen.
Date coding is where good intentions go to die. Every kitchen means to rotate stock and label opened items; far fewer do it consistently at 6pm on a Saturday with a delivery half-put-away. The failures are rarely dramatic — a tub of cooked chicken with no dot, a “best before” binned early as a “use by”, a defrosted salmon side back in the freezer. Individually minor, collectively they are among the commonest findings on a routine hygiene inspection. The fix is a system simple enough to survive a bad night: one label rule, one rotation rule, one place to write it down.
This guide is for the people who run UK food businesses — head chefs, kitchen managers, catering managers in schools, care homes and hospitals, deli and takeaway owners, and multi-site operators trying to make every venue label the same way. It covers date law, day-dot systems, opened shelf life, FIFO/FEFO rotation, defrost labelling and the records an EHO expects. When you are ready to equip the storage side, browse the food storage range at Craven Cooling.
Table of Contents
Step 1: Use-By vs Best-Before — The Legal Difference
Almost every date-coding error in a UK kitchen comes back to one confusion: treating a quality date as a safety date, or the reverse. The two are legally different animals, and knowing which is which decides whether food is binned needlessly, served dangerously, or handled correctly.
| Feature | Use-by | Best-before |
|---|---|---|
| What it means | Safety date — food may be unsafe to eat after it, even if it looks fine | Quality date — food is at its best until then, but safe to eat after |
| Selling past the date | ✗ A criminal offence | ✓ Legal, if the food is still fit |
| Typical foods | Cooked meats, dairy, ready-to-eat fish, prepared salads, sandwiches | Dried goods, tinned food, flour, pasta, frozen food, biscuits |
| Judged by | The date only — never smell, taste or appearance | Quality checks (staleness, rancidity) after the date |
| If storage failed | Date is void — food may be unsafe well before it | Quality drops faster, but no automatic safety risk |
A third label is worth knowing: display until or sell by. These are stock-control instructions for the retailer, not legal safety dates — never a substitute for a use-by. Where a “display until” sits alongside a “use by”, the use-by governs safety. Train staff to read past the retailer codes to the legal date underneath.
Step 2: Day-Dot & Date-Labelling Systems
The supplier’s date covers the unopened product. The moment you open, decant, cook or prepare, you take over responsibility for the shelf life — and that means your own label. Day-dot systems are the standard UK answer: a coloured or dated sticker that records when an item was opened or prepared and when it must be used by.
Day-of-the-Week Dots
Colour per day- Seven colours, one per weekday
- Fast visual check across a shelf
- Cheap, no printing needed
- Risk: colour without a written use-by
- Best paired with a wall key
Write-On Date Labels
Prepared / use-by written- Staff write prep date + use-by
- Unambiguous — no colour code to learn
- Works for agency and new staff
- Needs a reliable marker to hand
- Removable adhesive for wash-up
Dissolvable Labels
Wash-away in seconds- Dissolve fully in the wash
- No sticky residue on containers
- Keeps reusable tubs clean
- Ideal for high-turnover prep
- Slightly higher cost per label
Printed / Digital Systems
Label printers- Auto-calculates use-by from prep date
- Allergen & product name on label
- Consistent across every shift
- Best for multi-site standardisation
- Higher setup, lowest error rate
Whichever you use, a colour or dot alone is not enough — every labelled item needs, at minimum, what it is, the date it was opened or prepared, and the date it must be used by. Day-of-week dots are fine as a fast visual layer, but they must sit on top of a written use-by, not replace it. A red dot means nothing to an inspector without a key on the wall and a use-by they can read.
Not “later” — the dot goes on as the lid comes off or the batch is made. A tub with no dot must be treated as unknown and discarded; there is no safe way to guess when it was opened.
Three pieces of information, every time. “Cooked chicken · opened Tue · use by Wed” leaves nothing to interpretation at handover or on inspection.
Your dot supplements the manufacturer date — it never covers it up. Where possible, keep the original packaging or transcribe the supplier use-by so both dates are legible.
If you use coloured dots, a laminated key beside the fridges tells any staff member — and any inspector — what each colour means. No key, no defensible system.
Step 3: Opened Shelf Life & the 2-Day Rule
Once you open a use-by product, the manufacturer’s date was validated for the sealed pack — not for a tub that has been opened, portioned and handled. That is why kitchens apply their own opened shelf life, and the most widely used UK convention for high-risk ready-to-eat foods is the 2-day rule: the day of opening or preparation counts as day 1, and the food is used by the end of day 2.
The 2-day rule is a practical default, not a law of physics. Some foods deserve a shorter life — freshly cooked rice, cooked shellfish and certain dairy preparations can warrant same-day or 24-hour use. The default protects you when there is no better information; the manufacturer’s own guidance, where it exists, always overrides it.
Step 4: FIFO vs FEFO Stock Rotation
Labelling tells you when food expires; rotation makes sure the food that expires first is the food that gets used first. Two methods run UK kitchens, and using the wrong one for the wrong stock is a quiet source of waste and risk.
| Method | What it means | Rotate by | Best for |
|---|---|---|---|
| FIFO | First In, First Out — use the oldest delivery first | Date of delivery / receipt | Undated ambient stock: dry goods, tins, packaging where age tracks order of arrival |
| FEFO | First Expiry, First Out — use the soonest-to-expire first | Use-by / best-before date on the pack | Anything dated: chilled, fresh, short-life goods where a newer delivery may expire sooner |
FIFO is the rule everyone knows: newest to the back, oldest to the front, use front first — and it works when arrival order matches expiry order, which for dry ambient goods it usually does. FEFO is the sharper tool for dated stock, because deliveries do not always arrive in expiry order: a Thursday delivery of yoghurt can carry a shorter use-by than the Tuesday batch still on the shelf. Rotate that by delivery date and you serve the longer-dated tub while the shorter-dated one expires behind it. For anything carrying a date, expiry beats arrival every time.
Read the use-by on every dated item as it comes in, before it is put away. Reject anything with too short a life for your turnover, and note which existing stock it should sit in front of or behind.
Put the soonest-to-expire stock where it will be reached first. This is FEFO in one physical action — the hand naturally takes the front item.
The commonest rotation failure is a busy delivery shoved straight to the front of the shelf. Two minutes of loading correctly saves the waste of stock that quietly times out at the back.
A quick scan each morning for anything using-up today or tomorrow lets you plan specials, prep or freezing while the food is still safe — rotation as a cost tool, not just a compliance one.
- 11-litre sealed hopper — date-label the fill, not loose bags
- Portioned dispensing, product stays sealed from air and hands
- One fill = one use-by to track, not a shelf of open boxes
- Strips down for daily wash and sanitise
- Clear body makes remaining stock and rotation visible
A worked example of date control by design: a sealed, single-fill hopper you label once, rather than a row of half-open cereal boxes each timing out on their own. Fewer open dates to chase, cleaner rotation, and the 852/2004 answer to the open crock.
View Cereal Dispenser →Step 5: Defrost & Freezer Date Labels
Freezing is a pause button, not a reset. It stops the clock on quality and stops bacterial growth — but the moment food defrosts, the clock restarts, and freezer stock needs its own date discipline at both ends: going in, and coming out.
| Stage | What to label | Why it matters |
|---|---|---|
| Freezing down | Product name, date frozen, and a “use within” for frozen quality | Frozen food is safe indefinitely at −18°C but loses quality — a date frozen label stops mystery bags accumulating |
| Freezing prepared food | The original prep date and the frozen date both | You need to know it was in-date when frozen — freezing does not rescue food that was already at its use-by |
| Defrosting for use | A fresh use-by (commonly 24 hours, chilled at 8°C or below) | The frozen date is now spent — defrosted high-risk food behaves like fresh and needs its own short use-by |
| After defrost | “Do not refreeze” on raw defrosted product | Refreezing raw defrosted food is a food-safety failure — each freeze-thaw cycle raises risk and destroys quality |
The practical rules are simple and worth drilling. Never freeze food already at or near its use-by — freezing preserves the current state, it does not extend safety already gone. Defrost under control (in the fridge, not on a bench), and the moment food is defrosted, label it with a fresh use-by: for most high-risk items, use within 24 hours held at 8°C or below. And do not refreeze raw defrosted product — cooked food made from defrosted raw ingredients can be frozen once after cooking, but raw fish that has thawed does not go back in the freezer.
Step 6: Records & EHO Compliance
Retained Regulation (EC) 852/2004 requires a documented, HACCP-based food safety management system, and date control and stock rotation are prerequisite programmes within it. You do not need a folder the size of a phone book — you need a system an inspector can see working and a few records that show it runs when nobody is watching.
One page: how you label opened food, your opened-shelf-life defaults (the 2-day rule and exceptions), your rotation rule (FIFO/FEFO), and your defrost labelling. This is the “what we do” an EHO asks to see.
The colour key on the wall and an opened-shelf-life chart by the prep bench are both a training aid and evidence. They show the system is documented and used, not carried in one person’s head.
A simple daily date/rotation check and fridge-temperature log tie the whole system together — they show the dates you write sit on top of a cold chain that held. This is what turns “we do rotate” into proof.
Every food handler shown the labelling, rotation and defrost rules, with a signed line in the training record. Under 852/2004, food handlers must be trained appropriately — a signature moves the conversation from “did they know?” to “was it followed?”
What a Date-Control & Storage Setup Costs — July 2026
Indicative UK costs, July 2026, ex VAT. Set against the food a single mis-rotated week sends to the bin, a proper labelling and storage setup pays for itself fast.
In this guide ↓
- Key facts and the real date-coding law
- Use-by vs best-before — the legal difference that decides waste and risk
- Day-dot and date-labelling systems compared
- Opened shelf life and the 2-day rule, worked through
- FIFO vs FEFO and how to rotate dated stock
- Defrost and freezer date labelling
- Records and what an EHO actually checks
- FAQ — eight date-control questions answered
The Inspection-Day Checklist
Run this weekly. If every line passes, a date-and-rotation inspection holds no surprises.
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Every opened / prepared item is labelled Product, open or prep date, and a written use-by on every tub. No orphan containers, no mystery dots.
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Supplier use-by dates intact No use-by date altered, obscured or overwritten. Your dot supplements the manufacturer date, never replaces it.
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Nothing past its use-by on the shelf High-risk food at or past use-by is gone, not “used up tomorrow”. The nose does not overrule the date.
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Stock rotated shortest-date-first FEFO on dated goods, FIFO on ambient. Soonest to expire at the front; no new delivery stacked over old.
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Defrosted food re-dated A fresh use-by on anything taken out of the freezer; no raw defrosted product going back in.
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Fridges at 8°C or below and logged The cold chain the dates depend on is holding, and the temperature log proves it.
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Label key and shelf-life chart on display Colour code and opened-shelf-life defaults visible by the fridges and the prep bench.
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Procedure and training records current Written labelling and rotation procedure on file; every food handler signed off; date-check log up to date.
Date coding and stock rotation are the most inspectable parts of a UK HACCP plan. Two dates are legally distinct: use-by is a safety date and selling food past it is a criminal offence; best-before is a quality date and food is legal to sell afterwards. Never alter a supplier’s use-by — your own day-dot supplements it, recording what a food is, when it was opened or prepared, and when it must be used by. High-risk opened foods commonly follow the 2-day rule (day of opening = day 1), always taking the sooner of that default and any manufacturer instruction, and every date assumes storage at 8°C or below under the Food Safety (Temperature Control) Regulations 1995. Rotate ambient stock by FIFO and dated stock by FEFO, because the newest delivery is not always the soonest to expire. Defrosted food gets a fresh use-by (typically 24 hours chilled) and raw defrosted product is never refrozen. Retained Regulation (EC) 852/2004 requires all of this to sit inside a documented HACCP system with a written procedure, label key, shelf-life chart and check log — if it is not written down, the inspector assumes it did not happen. Craven Cooling (Swansea showroom) stocks food storage and containers and sources storage fridges and shelving to specification: 01792 732702 or sales@cravencooling.co.uk.
