FSA Consultation letter, 19 September 2002
In November 2001, the European Community agreed Commission Directive 2001/101, to introduce a Europe-wide definition of 'meat'; for labelling purposes. The new definition is narrower than the current definition provided by the Meat Products and Spreadable Fish Products Regulations 1984 (MPSFPR), and is thought to match more closely the consumer's perception of meat.
This and other changes in EU food labelling law mean that a revision of the UK regulations is necessary.
The Agency has, therefore, prepared the various documents on which comments would be appreciated.
The Meat Products (England) Regulations 2003
The new Meat Products Regulations (MPR) retain as many of the consumer protection measures of the MPSFPR, while bringing the national provisions into line with recent European legislation on labelling and relating to the new EC definition of meat.
The new Regulations will apply in England only. Separate but equivalent legislation will also be made by Scotland, Wales, and Northern Ireland who will be holding separate consultation exercises on those Regulations.
What are the provisions of the new Regulations?
The new MPR carry forward most of the compositional requirements of the MPSFPR. In summary, the new Regulations will:
The Agency has produced the attached Guidance Notes which provide practical advice for businesses and enforcement bodies, with the aim of achieving consistent application and enforcement of the new provisions. The Guidance Notes describe how meat products should be labelled under the new provisions (including the provision of QUID declarations) and explain the compositional requirements of the new MPR.
The Guidance also includes two methods for calculating the declarable meat content of products, as well as determining any excess fat or connective tissue. These methods enable manufacturers to base their calculations either on established typical values for fat and connective tissue, using the accepted visual lean system; or on analytical values for the ingredients used in the recipe.
It is important to note that the Guidance Notes are non-statutory, providing advice on best practice and should be read in conjunction with the relevant legislation. They should not be taken as an authoritative statement or interpretation of the law as only the Courts have this power.