A number of legal requirements affect butchers regarding the labelling and composition of fresh meat, cooked meat and meat products, eggs, and cheese.
Food for sale to consumers needs varying degrees of labelling. Beef and veal have specific legislation governing their labelling, while pork is not currently subject to the same sort of legal requirements. Specified meat products have a legal definition and very specific labelling requirements. If you are a butchers you also need to take care when using such terms as 'smoked' and 'traditional' as these are also subject to legal and restricted definitions.
Be aware that there are legal and restricted definitions of many terms used to describe the products discussed in this guide. Examples of these terms are:
- 'breast' - should be clear if products are made from chopped and shaped / reformed cuts of meat
- 'smoked' - should be distinguished from products that have not been smoked but contain 'smoke flavouring'
- 'lean' and 'extra lean' should be sufficiently different to standard products
- 'farmhouse', 'traditional', 'homemade' - these terms have specific meanings
- 'gluten free' - ensure your herb or spice mixes used in products are also gluten free
- 'kosher' and 'halal' have very specific legal definitions, and you should clarify with your slaughterhouse or supplier whether or not your products comply with these requirements
- 'free range', 'outdoor reared' and 'local' should be confirmed in writing by your supplier
Loose fresh meat displayed for sale should be labelled with the name of the food. The name of the food should be precise, giving the type of meat, and accurately describing any cut that you declare - for example, sirloin steak, frying steak, loin chops, or mutton mince. Meat that has been treated with proteolytic enzymes must be described as 'tenderised'.
Products must not contain more than the maximum permitted level of additives listed in the Food Additives, Flavourings, Enzymes and Extraction Solvents (Wales) Regulations 2013. Sulphur dioxide is only permitted in burger meat containing a minimum 4% rusk or vegetable content, or sausages, and at a set level of 450mg/kg. As it is an allergen, its presence must be declared.
If any meat product contains added proteins originating from a different animal, this must be stated in the name of the food.
If you produce or sell uncooked cured or uncured meat products with the appearance of a cut, joint, slice, portion or carcase of meat, and contain more than 5% water, you must include the words 'added water' in the name of the food.
If the meat product contains any other added ingredients apart from these, whether or not this needs to be included in the name of the food should be determined on a case-by-case basis in accordance with article 17 of EU Regulation (EU) No 1169/2011 on the provision of food information to consumers.
If herbs or any other products you have used have been irradiated, you must also include this on the label.
A limited number of types of fresh meat have protected designation of origin status, based on breed, geographical origin or farming method. A complete list of registered products from the UK is available on the GOV.UK website.
Beef and veal must be labelled in compliance with the Beef and Veal Labelling Regulations 2010.
While there are not legal requirements for pork labelling in the same way as for beef and veal, the Pork Provenance website has a code of practice that may be helpful.
However, fresh (and frozen) pork, poultry, lamb and goat meat have to be labelled with its origin.
A 'regulated product' is defined in the Products Containing Meat etc. (Wales) Regulations 2014 as: 'a food that contains one of the following as an ingredient (whether or not the food also contains any other ingredient): (a) meat; (b) mechanically separated meat; (c) the heart, the tongue, the muscles of the head (other than the masseters), the carpus, the tarsus, or the tail of any mammalian or bird species recognised as fit for human consumption'.
Meat products must be accompanied by a label with the name of the product, details of any allergens, irradiated ingredients and added water in excess of 5%, as for fresh meat. Additionally, many meat products - such as sausages, burgers, pasties and pies - are subject to compositional requirements.
When producing meat products, you will need to ensure your recipe and manufacturing method produces goods that comply with their legal definition, with particular regard to meat content.
Meat is defined as skeletal muscle with specified amounts of adherent tissue (connective tissue and fat); it does not include offal. The associated levels of fat and connective tissue that may be counted towards the meat content vary for different species. After this level is reached, then the connective tissue and fat must be declared separately on any ingredients label (for instance, pork rind or beef fat) and cannot be counted towards the meat content.
There are three methods currently used to work out meat content from a cut of meat. These are 'visual lean', 'CLITRAVI analysis' and 'nitrogen testing' (for single species only). A butchers' calculator is available from the Food Standards Agency.
Ensure that the labelling of the variety of any cheeses you sell loose is accurate. Many varieties of cheese have a Protected Designation of Origin. A complete list of UK registered products is available on the GOV.UK website.
Cheese does not require ingredients listing for lactic products, enzymes and microbiological cultures, only for added ingredients to the cheese (such as herbs or fruit) and the presence of allergens.
Failure to comply may result in an improvement notice being issued, requiring compliance to be achieved. If the improvement notice is not complied with it is an offence under the Food Safety Act 1990. The maximum penalty on conviction is an unlimited fine and/or two years' imprisonment.
If allergen information does not comply with the requirements it is an offence under the Food Information (Wales) Regulations 2014. The maximum penalty on conviction is a fine of £5,000.
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