Schedule 4 · Part II · Paragraph 5.2.5
Schedule 4 paragraph 5.2.5: stock rotation
The June 2026 final amendment requires covered food storage to follow First In First Out and First Expire First Out. The substituted paragraph says this requirement does not apply to retailers.
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Introduction
Paragraph 5.2.5 appears in Schedule 4, Part II under food operations and controls. The final amendment names raw materials, ingredients, work-in-progress and processed, cooked or packaged food products as the storage covered by FIFO and FEFO.
The final words exclude retailers from this particular paragraph. They do not replace other food-safety, storage, temperature, hygiene or product-specific requirements that may apply to a retailer.
Key takeaways
Use both rotation principles
The amended paragraph states First In First Out (FIFO) and First Expire First Out (FEFO) for covered storage; date of receipt and expiry or use-by information should therefore be visible in the process.
Cover the named stock
The text includes raw materials, ingredients, work-in-progress and processed, cooked or packaged products.
Retailers are excepted here
The final paragraph says the FIFO/FEFO requirement in 5.2.5 is not applicable to retailers; other applicable food-safety duties remain a separate check.
Map stock categories
Identify receiving, work-in-progress and finished-food storage points for the covered operation. Include ingredients and processed, cooked or packaged stock, not only finished goods.
Record dates used for rotation
For covered stock, retain receipt or production dates and expiry or use-by details where supplied so FIFO and FEFO can be applied in storage and picking. Resolve stock with a nearer expiry even if it arrived later.
Apply the retailer exception narrowly
If the operation is a retailer, paragraph 5.2.5's substituted FIFO/FEFO requirement does not apply to it. Where the same business also carries on non-retail licensed activities, assess those activities separately.
Practical checklist
Do
- Check the food-business activity and applicable Schedule 4 part.
- For covered storage, train staff to use both receipt and expiry information.
- Keep stock-control evidence proportionate to the operation.
Avoid
- Do not present this particular paragraph as a universal retailer duty.
- Do not treat the retailer exception as a general exemption from safe food storage.
FAQs
Does the amended FIFO/FEFO paragraph apply to retailers?
The final June 2026 wording says paragraph 5.2.5 is not applicable to retailers. A retailer should still check all other applicable food-safety and storage requirements.
Official sources
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