What are TCS foods? FDA Food Code examples and temperatures
TCS foods need time and temperature control to limit pathogen growth. See FDA Food Code examples, 41°F and 135°F holding, cooling and reheating rules.
What are TCS foods?
TCS stands for time/temperature control for safety: TCS foods need these controls to limit pathogen growth or toxin formation. Under the FDA Food Code, cold TCS food is generally held at 41°F (5°C) or below and hot TCS food at 135°F (57°C) or above, with a few specific exceptions (FDA Food Code 2026, definition; holding rules).
FDA released the 2026 Food Code on September 17, 2026. It is a model code that states and local agencies adopt, sometimes with changes, so check which edition your jurisdiction enforces.
TCS food definition and examples
Protein alone doesn't decide TCS status. Section 1-201.10 names these groups:
- raw or heat-treated animal food, such as meat, fish and eggs
- heat-treated plant food, such as cooked rice
- raw seed sprouts
- cut melons
- cut leafy greens, such as shredded lettuce
- cut tomatoes and mixtures of cut tomatoes, unless modified so pathogens can't grow or form toxin
- garlic-in-oil mixtures, unless modified the same way
Cut leafy greens means shredded, sliced, chopped or torn leaves. It excludes herbs such as cilantro and parsley (definition).
Classification also uses pH and water activity together. Foods marked "PA" need a product assessment and stay TCS unless that assessment shows growth or toxin formation is prevented. There is no universal pH cutoff (classification tables).
Exclusions include air-cooled hard-boiled eggs with intact shells, and intact-shell eggs that are not hard-boiled but were pasteurized to destroy Salmonella. Unopened hermetically sealed food that stays commercially sterile without refrigeration is excluded too. Non-TCS doesn't mean hazard-free.
TCS food temperatures
| Step | General Food Code rule | Source |
|---|---|---|
| Receiving cold TCS food | 41°F (5°C) or below | 3-202.11 |
| Receiving cooked hot food | 135°F (57°C) or above | 3-202.11 |
| Cold holding | 41°F (5°C) or below | 3-501.16 |
| Hot holding | 135°F (57°C) or above | 3-501.16 |
| Cooling cooked TCS food | 135°F to 70°F (21°C) within 2 hours, and to 41°F within 6 hours total | 3-501.14 |
| Reheating cooked, cooled food for hot holding | 165°F (74°C) throughout for 15 seconds, within 2 hours from 41°F | 3-403.11 |
The correct temperature for receiving cold TCS food is generally 41°F or below. Distribution laws can set other limits, including for some milk and shellfish. Raw shell eggs need refrigerated equipment with ambient air at 45°F (7°C) or below. Food shipped frozen must arrive frozen, and TCS food must show no evidence of earlier temperature abuse (receiving exceptions).
Holding exceptions include qualifying roasts at 130°F (54°C) or above, and untreated shell eggs in equipment at 45°F ambient air or below. The general limits do not apply during preparation, cooking, cooling or a compliant time-as-control procedure (holding rules).
The cooling clock is 6 hours total, not 2 hours plus another 6. Food made from room-temperature ingredients must reach 41°F within 4 hours. Food lawfully received above 41°F generally has that same 4-hour limit. Raw eggs received that way instead go straight into equipment holding ambient air at 45°F or below (3-501.14). Methods include shallow pans, smaller portions, rapid-cooling equipment, stirring in an ice-water bath and other effective methods (3-501.15).
The 2026 edition adds one alternative: food no more than 2 inches deep, uncovered, in refrigeration holding air at 41°F or below, with continuous electronic monitoring of time and air temperature (3-501.15; summary of 2026 changes). Use it only with regulatory-authority approval. It does not apply to cooling under 3-401.14(B), 3-502.12(D)(2)(e) or 3-501.19, and a shallow pan alone doesn't qualify.
Qualifying commercially processed, packaged ready-to-eat food from an inspected plant needs reheating to at least 135°F for hot holding. Qualifying unsliced roasts have a separate route. Microwave reheating also needs stirring or rotation, a cover and a two-minute covered stand. Cooked, refrigerated food for one customer's order may be served at once at any temperature (3-403.10 and 3-403.11).
Ready-to-eat TCS food date marking
Refrigerated ready-to-eat TCS food held more than 24 hours must be marked for use, sale or discard within 7 days at 41°F or below. The day of preparation, or the day a commercial package is opened, counts as Day 1 (3-501.17). Mixed dishes keep the earliest relevant ingredient date. Don't exceed a manufacturer's safety-based use-by date. Some inspected-plant products are exempt. That is not a pass for every salad, cheese or sausage.
Time and temperature abuse
In practice, time and temperature abuse means food has missed a holding, cooling, reheating or receiving limit. Using time as a public health control needs advance written procedures and a time mark. The 4-hour route starts at 41°F or below, or 135°F or above. The 6-hour route starts at 41°F or below, requires temperature monitoring and must stay at 70°F or below. Food must be served or discarded by the applicable deadline. No mark, or a breached limit, means discard. It is not a general six-hour unrefrigerated allowance (3-501.19).
RegAffairs AI has a public answer thread on TCS foods with Food Code citations for the definition, holding, cooling and reheating rules.