Answers · Health inspections

Date Marking, Labeling & Food Storage Questions & Answers

Restaurant date marking and food labeling answers: the 7-day rule, use-by vs sell-by dates, FIFO, storage order, prep labels, and what inspectors check.
Plain-English answers to common questions. Educational, not legal advice — confirm specifics with your local authority.
Ready-to-eat / cooked food (top) Seafood — 145°F Whole cuts of beef / pork — 145°F Ground meat — 155°F Poultry (bottom) — 165°F TOPBOTTOM Store by minimum cook temperature — higher cook temp goes lower.
Raw-food storage order: shelve by minimum internal cook temperature, lowest on top. Ready-to-eat food sits above everything; raw poultry (165°F) goes on the bottom so drips can’t contaminate food below.

Date marking, labeling, and correct storage keep track of how long food is safe and prevent the mix-ups that lead to violations and illness. These answers cover the seven-day rule, use-by dates, FIFO, cooler storage order, and prep labels. Figures follow FDA Food Code concepts and vary by state and local jurisdiction.

What is a date mark on food?

A date mark is a label showing when a ready-to-eat, time/temperature control for safety (TCS) food was prepared or opened, and the date by which it must be used or discarded. It lets staff and inspectors track how long the food has been held under refrigeration. For example, house-made deli salads or opened deli meats get a date mark so no one keeps them past the safe limit. Date marking is a basic food-safety control inspectors check regularly. The exact requirements vary by jurisdiction.

What is date labeling in a commercial kitchen?

Date labeling is the practice of marking prepared and opened foods with dates so the kitchen knows their age and when to discard them. It covers ready-to-eat TCS foods held longer than 24 hours, using a prep date, an open date, and/or a discard (use-by) date. Common systems use day-of-the-week color dots or write-on labels. Consistent date labeling supports stock rotation, reduces waste, and is a routine inspection item. What must be labeled and how is set by the local food code.

Which foods require date marking?

Date marking generally applies to ready-to-eat, TCS foods that are prepared on-site or opened from a commercial package and then held under refrigeration for more than 24 hours. Examples include cooked meats, cut leafy greens, cut melons, cooked rice and pasta, house-made sauces and salads, and opened deli meats or dairy. Foods that are not TCS, or that are used or discarded within 24 hours, typically do not need a date mark. Because definitions and exemptions vary by jurisdiction, confirm the specifics with your local code.

How long can ready-to-eat TCS food be kept under the date-marking rule?

Under the FDA Food Code, ready-to-eat TCS food prepared and held on-site may be kept for up to 7 days when stored at 41 degrees F or below, counting the day of preparation as day one; after that it must be discarded. Holding at a warmer temperature shortens the safe period. The 7-day maximum is the general standard, but some states or localities set different limits or conditions, so verify the rule that applies to your jurisdiction.

Does the 7-day date-marking count include the day the food was prepared or opened?

Yes. Under the FDA Food Code, the day the food is prepared or the package is opened counts as day one, so the food must be used or discarded within seven days including that first day, when held at 41 degrees F or below. In practice, that means a food prepped on the first day carries a discard date six days later. Kitchens often pre-print or write the discard date to avoid confusion. Counting conventions can vary slightly by jurisdiction, so follow local guidance.

What's the difference between use-by, sell-by, and best-by dates?

On commercial packages these are manufacturer quality dates, not food-code safety marks. 'Sell-by' tells the store how long to display the product; 'best-by' (or 'best if used by') indicates peak quality; 'use-by' suggests the last date for best quality, and for a few products relates to safety. Most are about quality rather than a hard safety cutoff. In a restaurant, the food code's own date-marking (the 7-day rule for opened/prepared TCS foods) is what governs safety once you open or make the food.

Do sell-by and use-by dates mean the same thing?

No. A 'sell-by' date is guidance for the retailer on how long to keep a product on the shelf, and food is often still fine for a time after it. A 'use-by' date is aimed at the consumer and marks the last date the manufacturer recommends for peak quality, and for certain perishable items it leans toward safety. Neither is federally standardized for most foods. In a restaurant, once you open or prepare the item, your own date marking under the food code takes over.

For most commercially packaged foods, a passed 'best-by' or 'sell-by' date reflects quality, not safety, so using the product is not automatically illegal, provided it is still wholesome, was stored properly, and shows no signs of spoilage. However, once a package is opened, the food code's date-marking clock (commonly 7 days at 41 degrees F) applies. Certain items with true safety-based dates, and any spoiled food, must not be used. Rules on specific date-labeled products vary by state and jurisdiction, so check local code.

What is FIFO (first in, first out)?

FIFO stands for 'first in, first out,' a stock-rotation method where older inventory is used before newer stock. When new deliveries arrive, they go behind or below existing product so staff naturally reach for the oldest items first. Combined with date marking, FIFO ensures food is used within its safe window and reduces spoilage and waste. It applies to dry storage, coolers, and freezers alike. Inspectors look for evidence of rotation, such as dated, organized shelves, as a sign of good inventory control.

How does FIFO improve food safety?

FIFO reduces the chance that food is forgotten and held past its safe life, because staff consistently use the oldest, soonest-to-expire items first. Pairing FIFO with clear date marking means expired product is caught and discarded rather than accidentally served. It also curbs waste and keeps storage organized so inspectors and staff can quickly spot out-of-date items. While FIFO alone does not guarantee safety, it is a simple, effective habit that supports temperature control and date-marking rules and prevents the buildup of aging stock.

Do I have to label food I prepare in-house?

Yes, for ready-to-eat TCS foods held more than 24 hours, in-house prepared items must be date marked so their age and discard date are clear. Labeling typically shows what the item is (helpful when contents are not obvious) and the prep or discard date. This applies to batch-cooked proteins, cut produce, sauces, and similar foods. Same-day-use items usually do not require it. Unlabeled prepared food in the cooler is a frequent violation. The precise labeling requirements are set by your local food code.

What information should go on a food prep label?

A useful prep label identifies the food, the date (prep date and/or discard/use-by date), and often the person or shift that made it. The discard date makes it easy for anyone to know when the item must go, without recalculating the 7-day window. Some kitchens add the time for foods with tighter limits. Keeping labels consistent, legible, and food-safe (using removable or dissolvable labels) helps rotation and inspections. Minimum required information varies by jurisdiction, but the date is the essential element.

How should raw meats be arranged in the cooler?

Store raw animal proteins by their required minimum cooking temperature, with the lowest-cook-temperature items on top and the highest on the bottom, and keep all raw items below ready-to-eat foods. A typical top-to-bottom order is: ready-to-eat foods, then raw seafood, then whole cuts of beef and pork, then ground meats, with raw poultry on the very bottom. This prevents juices from a food that needs a higher cook temperature from dripping onto one that needs less cooking. Cover and date-mark items, and this order is standard across jurisdictions.

Why is raw chicken stored on the bottom shelf?

Raw poultry requires the highest cooking temperature (typically 165 degrees F) to be safe, which reflects the higher pathogen risk it carries, so it is stored on the lowest shelf. Placing it at the bottom ensures that if any juices drip, they fall away from, not onto, foods that are cooked to lower temperatures or eaten raw. Storing chicken above other foods is a classic cross-contamination hazard and a common violation. Keeping it covered, contained, and on the bottom is a simple, reliable safeguard.

What is the correct top-to-bottom order for storing raw foods?

Order shelves by minimum internal cooking temperature, lowest on top, highest on bottom, with ready-to-eat foods above everything. A common sequence from top to bottom is: ready-to-eat and cooked foods; raw seafood; raw whole cuts of beef and pork; raw ground meats; and raw poultry on the bottom. This arrangement keeps higher-risk drippings away from lower-risk or ready-to-eat items. It applies within a single cooler and in walk-ins. The principle is consistent nationwide, though inspectors expect to see it correctly followed and the food covered.

How long can opened deli meat or lunch meat be kept?

Once a commercial package of deli meat is opened, it becomes subject to the food code's date-marking rule, commonly up to 7 days total when held at 41 degrees F or below, counting the day it was opened as day one. House-sliced or prepared meats follow the same window. Mark the open date and discard date, rotate with FIFO, and toss it when the window closes or if quality declines. Some products carry their own shorter use-by guidance. The exact limit can vary by jurisdiction and product.

How long does house-made prepared food last in the walk-in?

Ready-to-eat TCS foods made in-house can generally be held up to 7 days at 41 degrees F or below, counting the prep day as day one, then must be discarded. Warmer holding temperatures shorten that. Quality may decline before the safety limit, so judgment and rotation matter too. Date-mark every batch, use FIFO, and check temperatures to make sure the cooler stays at or below 41 degrees F. The 7-day maximum is the general FDA Food Code standard; confirm your local jurisdiction's specific rule.

Does freezing pause the date-marking clock?

Yes, in effect. Under the Food Code, if you freeze a date-marked ready-to-eat TCS food, the days it spends frozen do not count toward the 7-day limit; the clock stops while frozen and resumes when the food is thawed. You must retain the original date information and mark the freeze and thaw so the remaining days can be tracked. For example, food frozen on day two has five days left once thawed. Document this clearly, as handling and record-keeping expectations vary by jurisdiction.

What date do I put on food I pull from the freezer to thaw?

Keep the food's original date-mark information and note the date it was removed to thaw, so you can resume counting the remaining days of its 7-day window (the frozen time does not count). The food must then be used within whatever days were left before it was frozen. Clearly label it with the thaw date and the resulting discard date to avoid confusion during service. Because record-keeping methods differ, follow your local health department's guidance on documenting frozen and thawed date-marked foods.

Do commercially packaged foods need a date mark once opened?

Yes, if they are ready-to-eat TCS foods held longer than 24 hours after opening. Once you open the package, the manufacturer's seal no longer governs and the food code's date-marking applies, commonly a 7-day limit at 41 degrees F or below, counting the open day as day one. Examples include opened deli meats, dairy, and prepared refrigerated items. Unopened commercial packages rely on the manufacturer's dating, but once opened, mark them. Specific requirements and any exceptions vary by jurisdiction.

At what temperature does the 7-day date-marking rule apply?

The 7-day maximum for ready-to-eat TCS food assumes the food is held at 41 degrees F or below the entire time; the cold temperature is what limits bacterial growth enough to allow a week of storage. If food is held warmer than 41 degrees F, the safe window shrinks and the 7-day rule no longer applies. That is why cooler temperature monitoring goes hand in hand with date marking. Some jurisdictions permit slightly different holding temperatures or shorter windows, so verify the standard your local code uses.

Can I combine two batches of food with different prep dates?

It is discouraged, and if you do combine them, the mixed product must carry the discard date of the oldest ingredient, not the newest, so you never extend the safe life of older food. Better practice is to keep batches separate, rotate with FIFO, and avoid topping off older food with fresh. Combining can also make date tracking confusing and lead to serving expired product. If combining is unavoidable, label with the earliest applicable discard date. Specifics may vary by jurisdiction, so follow local guidance.

Does date marking apply to food held hot?

Date marking is aimed at refrigerated ready-to-eat TCS foods; food that stays in hot holding at 135 degrees F or above is governed by hot-holding time and temperature rules instead. However, once hot food is cooled and stored in the cooler as a ready-to-eat leftover, it becomes subject to date marking and the 7-day window. So the concern shifts from date marks to holding time while the food is hot, and back to date marking once it is chilled for later use. Rules vary by jurisdiction.

What's the best way to date-label food in a busy kitchen?

Use a simple, consistent system everyone follows. Many kitchens use color-coded day-of-the-week dot labels, dissolvable or removable labels, or a label printer, and pre-print discard dates so staff do not have to calculate. Standardize where labels go and what they include (item and discard date), train every shift, and pair labeling with FIFO so older stock is used first. Keep markers and labels at prep stations. The goal is that anyone can glance at a container and instantly know whether it is still safe to use.

Is unlabeled or undated food a health code violation?

Often, yes. Ready-to-eat TCS food that requires a date mark but has none is a common citation, because inspectors cannot verify its age and staff may unknowingly serve expired product. Missing labels on prepared foods held more than 24 hours are flagged during storage checks. The fix is a reliable labeling routine. Foods used within 24 hours or non-TCS items may be exempt. Whether and how strictly it is cited depends on the item and the jurisdiction, but consistent date marking avoids the problem.

How long can I keep leftovers or prepped food before discarding it?

Ready-to-eat TCS leftovers and prepped foods can generally be kept up to 7 days at 41 degrees F or below, counting the day they were made or opened as day one, then must be discarded. Warmer storage shortens that window, and repeated cooling and reheating further reduces safe life. Date-mark everything, rotate with FIFO, and discard on the use-by date even if the food still looks fine, since harmful bacteria are not always visible. The 7-day standard is typical; confirm your local jurisdiction's limit.

What does a discard date mean?

A discard date (or use-by date under date marking) is the last day a ready-to-eat TCS food may be safely used, after which it must be thrown out, even if it looks and smells fine. It is calculated from the prep or open date plus the allowed holding period (commonly up to 7 days at 41 degrees F or below, counting day one). Putting the discard date directly on the label removes guesswork for staff. Discarding on time prevents serving food that may harbor harmful bacteria. The window can vary by jurisdiction.

Do I need to date-mark food that will be used the same day?

Generally no. Ready-to-eat TCS food that is prepared and then used or discarded within 24 hours typically does not require a date mark, since it will not be held long enough to reach the multi-day limit. Once food is held beyond 24 hours, date marking applies. Even so, many kitchens label everything for organization and rotation. Relying on the 24-hour exemption requires discipline so nothing lingers unlabeled past a day. The exact exemption and how it is applied can vary by jurisdiction.

How do inspectors check date marking during an inspection?

Inspectors open coolers and walk-ins and look at prepared and opened ready-to-eat foods to confirm they are labeled with correct, legible dates and are within their safe window. They may spot-check discard dates, ask staff how the system works, and look for expired or unlabeled items, all signs of whether the kitchen has real control over food age. Finding out-of-date or unmarked food is a common citation. Keeping a consistent labeling routine and discarding on time is the reliable way to pass this check.