declaration of added ingredients in meat products
The Food Standards Agency (FSA) has recently issued detailed new
guidance on the labelling of added ingredients in meat products
covered by Regulation 5 of the Meat Products Regulations. These are
any meat product whether raw or cooked, or cured with the
appearance of a meat cut, joint, slice, portion or carcase – ie
appearing like ‘whole meats’. These include white meats such as
rabbit and poultry products, red meats such as pork, lamb and beef
products, ham, bacon and other cured meats and game meat
products.
This guidance is intended to clarify the legal position in
relation to the labelling of added starch and/or protein in
regulation 5 meat products following changes to European
legislation and consequent amendment of the Meat Products
Regulations in this respect and to address issues in relation to
mislabelling problems of added water and the undeclared presence of
pork and beef hydrolysed proteins in these meat products.
The labelling of meat and poultry products with added water and
other ingredients is mainly controlled by the Food Labelling
Regulations 1996 (as amended) (FLR) and the Meat Products
Regulations (as amended) MPR. The FLR require food to be labelled
with a name which indicates its true nature and which enables it to
be distinguished from products with which it could be confused. The
FLR also require the meat content to be declared either in the
ingredients list or next to the name of the food and added water
used as an ingredient must generally be shown in the list of
ingredients when it exceeds 5% of the finished product.
Under the MPR, where added water makes up more than 5% of the
weight of the product for cooked and uncooked meat or cooked cured
meat and more than 10% of the weight of the product for uncooked
cured meat, it must be mentioned in the name of the food. In
addition, under the MPR, any other added ingredient of a different
animal species to the meat must also be declared in the name of the
food.
Prior to 2008 when changes to the EU Hygiene legislation where
introduced, the MPR also contained specific requirements covering
the declaration of added starch and protein in the name of these
meat and poultry products where they had not been added for a
technological purpose. These requirements under the MPR have now
been disapplied. However, the addition of starch and protein is
still covered by the Food Labelling Regulations, which means that
any added starch or protein would need to be declared in the name
of the food of the meat product if not to do so would mislead the
consumer about the true nature of the food or would not enable the
food to be distinguished from products with which it could be
confused. Furthermore, under the Food Safety Act 1990, the General
Food Law Regulation and the Consumer Protection from Unfair Trading
Regulations 2008, it is an offence to sell a food with a misleading
description.
It is emphasised that the separate requirement in the MPR to
declare in the name of the food ingredients of animal origin if
they come from a different species to the meat continues to apply.
Therefore, where, for example, pork or beef proteins are used in
poultry products the requirement to declare them in the name of the
food will continue.
While it is difficult to be specific about when added starch and
protein would be required to be in the name of the food in order to
comply with the FLR, the FSA is of the view that if the starch or
protein is used to bulk out the meat product or act as a meat
replacer, this might result in the starch or protein having to be
declared in the name of the food. For other situations where the
starch or protein is not being used to bulk out the food, in
deciding whether or not including starch or protein in the name of
the food is required, the Guidance advises consideration of issues
such as the amount of starch or protein added, whether consumers
would normally expect such ingredients, the range of similar
products on the market and whether they too have added starch or
protein.
