Meat Content Labelling
Q. Why has this legislation come into force?
A. Directive 2000/13/EC on the labelling, presentation and advertising of foodstuffs was amended by Commission Directive 2001/101/EC to tighten up the definition of “meat” for the labelling of meat based products such as pies, pasties, cooked meat, prepared dishes and canned meat.
The previous definition of meat made no distinction between muscle-meat, fat and offal, whereas consumers generally perceive meat to mean muscle-meat.
Q. What does the new meat content labelling legislation specify?
A. Firstly, the legislation restricts the definition of “meat” to the skeletal attached muscles only. Therefore any other parts of the animal for human consumption other than skeletal attached muscles such as heart, liver, kidney, tongue or even fat must now be declared separately in the list of ingredients.
Secondly, the species from which the meat came must also be declared. If the species name is being used, such as poultry, porcine, ovine, the name must be followed by the word “meat” e.g. Poultry meat. However, if the generic name is being used on the product label such as chicken, pork, lamb, then the word “meat” can be omitted.
Q. Does the legislation only apply to packaged products?
Yes. The legislation applies only to packaged products which contain meat as an ingredient.
Q. Has this EU legislation been transposed in to Irish legislation?
Yes, S.I. No. 257 of 2003 implements Commission Directive 2001/101/EC which applies to the labelling of products which contain meat as an ingredient.
Q. What is the benefit of this meat content labelling legislation?
This legislation makes it possible for the consumer to distinguish how much meat is actually present in any meat based product and also how much fat or connective tissue is actually present, allowing consumers to make more informed choices about the meat based products they buy.
Q. Does this legislation cover chicken nuggets and breaded meat products?
Yes. The meat labelling requirements apply exclusively to the labelling of products which contain meat as an ingredient, such as chicken nuggets, burgers, sausages, pies, pasties, wraps and goujons.
Q. What products are not affected by this new meat content labelling legislation?
This legislation is not applicable to meat which is sold without further processing, such as steaks, chops and cutlets or to anatomical parts such as ribs, chicken wings and chicken legs.
Q. Are there any exemptions from the meat content labelling legislation?
Yes. The legislation does not apply to cuts of meat and anatomical parts which are processed but in which the anatomical structure is still recognisable eg. Cooked Roast Chicken Breast.
Q. Does the definition of meat include fat and connective tissue?
A certain amount of fat and connective tissue is allowed for in the definition of ‘meat’ i.e. the fat and connective tissue that adheres to the muscles. This is subject to certain limits which are laid down in the legislation as follows:
|Species||Fat (%)||Connective Tissue ** (%)|
|Birds and Rabbits
*Other than rabbits and porcines
**In order to determine the connective tissue content of muscle-meat, the ratio of the collagen content to protein is calculated.
Q. What if the levels of fat and/or connective tissue in my product exceed the limits set out in the legislation?
A. If the limits for fat and connective tissue are exceeded then the excess fat and connective tissue must be listed separately in the list of ingredients.
Q. How do I calculate the meat content of my product?
A. The FSAI's Guidance Note 14 - The Application of Commission Directive 2001/101/EC as Amended by Commission Directive 2002/898/EC on the Definition of Meat provides details on the calculation of the meat content using a typical recipe for a pork liver sausage. The calculation steps can be summarized as:
1. Determine the product composition at the level of mixing bowl and identify all meat ingredients.
2. Group meat cuts by species and calculate meat ingredients contribution to recipe by species.
3. Determine fat, connective tissue and protein content for each species.
4. Calculate the maximum allowable connective tissue content in the meat mixture for each species expressed as collagen.
5. Calculate excess connective tissue content if any.
6. Calculate the maximum allowable fat content in the meat mixture for each species
7. Calculate excess fat content
8. Calculate the meat content per species
9. Express meat content as a proportion of the mixing bowl ingredients per species
10. Repeat the previous steps (3-9) for each species separately.
Appendix 3 of Guidance Note No. 14 gives typical values for protein, collagen and fat in meat cuts.
Q. When using bacon as an ingredient in a product, how is the calculation carried out?
As there are no values (% protein, % connective tissue, % fat, % collagen) for bacon given in the tables in Appendix 3 of Guidance Note No.14, bacon cannot be included in the meat content calculation. Therefore, if bacon is used the percentage bacon should be given separately in the list of ingredients.
Q. How should mutton as an ingredient be labelled?
When labelling mutton as an ingredient in a meat based product, it must be labelled as either the species name i.e. sheep meat or by the generic name i.e. mutton. It cannot be labelled as lamb.
Q. Does this legislation apply to salami, pepperoni and other sausage-type products?
Yes. The meat labelling requirements as of Directive 2001/101/EC apply exclusively to the labelling of products which contain meat as an ingredient including salami, pepperoni or similar products. Other parts of animals for human consumption used in a meat based product recipe, and fat and connective tissue which are in excess of the set limits, must be declared separately in the list of ingredients.
Q. What about Quantitative Ingredient Declaration (QUID) and products containing meat as an ingredient?
In certain circumstances, it is necessary to state on the label, the quantity, in percentage terms, of an ingredient used in the manufacture or preparation of a foodstuff. The percentage quantity should be labelled in or next to the name of the food or be in the list of ingredients next to the name of the ingredient. Meat based products like all pre-packaged food products will require a QUID in certain circumstances. For example, the list of ingredients of a ‘Beef Bolognaise Sauce’ could read:
Ingredients:Beef (20%), Water, tomato, tomato puree, onion, carrot, celery, modified starch, salt, sugar, garlic, oregano, pepper, basil
More details on quantitative ingredient declaration (QUID) can be found in the FSAI The Labelling of Food in Ireland 2007 report.
Q. How should dehydrated ingredients be included in the QUID calculation?
Where a recipe contains dehydrated meat ingredients, the calculation should treat these ingredients on the basis of their weight, and of their fat and connective tissue level, when rehydrated.
Therefore, it is also important to deduct from the weight of the ‘non-meat ingredients’ the weight of the water included in the recipe for the purposes of re-hydrating the dehydrated ingredients (otherwise the water will effectively be counted twice). An example is set out on page 39 of the FSA guidance document on http://www.food.gov.uk/multimedia/pdfs/meatguidance.pdf
Q. What about calculating QUID for cooked meats where water may have been lost during cooking?
For a meat based product which is subsequently cooked e.g. cooked ham, the quantity declaration for the meat ingredient may be based on the weight of the ingoing meat ingredients. However, this can result in the quantity of ingoing meat ingredient being greater than the weight of the final product due to water lost during cooking, and the QUID declaration would be greater than 100%. As this could be confusing to the consumer it is recommended that in addition to the QUID declaration, the weight of ingredient used to prepare 100g of the finished product should be indicated.
For example, for a cooked ham product: Pork (110% made with Xg pork per 100g)
Last reviewed: 17/9/2009