Food Law News - UK - 2001
FSA Letter, 11 October 2001
LABELLING / COMPOSITIONAL STANDARDS - EC Definition of Meat
The European Community has recently agreed [See EU News pages: 21
August 2001] a Commission Directive that provides a generic definition
of meat for labelling purposes. Member States are required to implement the new
Directive by 1 January 2003. The FSA is seeking views on the implications of the
new definition of meat for the Meat Products and Spreadable Fish Products Regulations
1984 (MPSFPR). Views will assist in the revision of the Regulations, which will
be the subject of a formal and fuller consultation.
Food Labelling Regulations 1996
The Commission Directive introduces the new meat definition by amending the Annex covering generic names in the Food Labelling Directive (2000/13/EC). The starting point for national implementation, therefore, will be an amendment to Schedule 3 of the Food Labelling Regulations 1996. This will standardise the labelling of all meat products especially for the purposes of quantitative ingredient declaration (QUID).
Meat Products and Spreadable Fish Products Regulations 1984
Specific labelling or compositional requirements for meat products have been in place for many decades as meat products, especially traditional ones such as sausages, burgers and pies, play a significant part in the UK diet. A large proportion of these products is sold non-prepacked and consumed in catering. There are other aspects of consumer protection in the MPSFPR, apart from the labelling, meat content and added water declaration that have served consumers well for many years. It is important therefore to consider the relevance of these provisions and whether they need to be retained. In particular the FSA would like views on the following questions:
The FSA would be grateful for views on the above questions and any other issues raised by the implementation of the new definition of meat by 9 November 2001.
- Should a QUID declaration apply to non-prepacked meat products? Currently a minimum meat content declaration is required to be displayed on a ticket or notice for most meat products sold non-prepacked at retail. Minimum meat content has been replaced by QUID, and should the QUID information on meat (species) content under the new definition continue to be given on a ticket or notice?
- Should the prohibition of the use of certain parts of the carcase in uncooked meat products continue? Currently there are many parts of the carcase that are not permitted in uncooked meat products, and these are listed in Schedule 2 Part II of the MPSFPR. This prohibition goes back almost fifty years, and is quality rather than safety based. Should it continue? (Note - separate Specified Risk Material (SRM) prohibitions apply)
- Should the reserved descriptions of certain meat products be retained? Schedule 4 of the MPSFPR gives a list of meat products where the name is protected and is linked to minimum meat content. Products that are covered include burgers, sausages, meat pies, corned (beef), meat and fish pastes, and paté. This ensures that where the name is used in retail or catering, the products will meet the minimum meat content requirement. Should these reserved descriptions be retained? If so, which products should be retained, which removed, and are there new products to be included?
- What should be the basis of the minimum meat contents for reserved descriptions? The new EU definition of meat not only gives clearer information to the consumer, but it could also be used to assist the enforceability of reserved descriptions under the MPSFPR. At the moment compositional requirements for meat products with reserved descriptions include specific restrictions on the amount of fat, by means of minimum total meat content and minimum lean meat, but not for connective tissue. Two options are possible:
- Remove minimum lean meat requirements, and introduce new minimum meat contents equivalent to the existing ones, but adjusted to take account of the new definition of meat. This will put minimum requirements for reserved descriptions on the same basis as the declared meat contents and which include limits on fat and connective tissue on the declared contents; or
- Retain the minimum meat contents based on lean meat only e.g. a pork sausage would require a minimum lean meat content of 32.5%. Lean meat would need to be defined on the basis of the new definition of meat i.e. with the connective tissue limits, but free of [visible] fat. Although this approach would reflect existing compositional requirements, the compositional minimum and the declared meat content (QUID) would be on a different basis. The advantage of this approach would be that it should not require any major changes to current practices for manufacturers large or small.
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