CFG
38/07 final
Letter dated 30 November
2007 from Foodaware to Richard Wood, Standards and Sustainability
Branch, Food Standards Agency:
Dear Mr Wood
FSA consultation on the Meat Products (England) (amendment)
Regulations 2008 and associated guidance on the labelling of added
ingredients in meat products
Foodaware members have a particular interest in food labelling and,
in the past, have expressed concerns about issues such as added
water in meat products and the importance of declarations of added
ingredients in meat products. It is essential, as the consultation
acknowledges, for consumers to be able to judge the quality and
content of such products for competition to be fair.
The changes proposed by FSA are intended to bring labelling requirements
for added starch and protein in meat products (that look like a
cut, joint, slice, portion or carcase of meat or cured meat) into
line with EU requirements and to improve the guidance available
to the industry and enforcement bodies.
Consumers would not generally expect added ingredients in meat products
that look like sliced whole, cooked or cured meat, so it is important
that where additional starch or protein is added its presence is
clear. The consultation acknowledges that problems with labelling
of added ingredients have been found in the UK and EU, and that
different practices have been followed by producers. This can result
in abuse from unscrupulous suppliers and confusion among consumers.
It appears that the confusion has arisen at least in part by the
differing requirements of Regulation 5 of the Meat Products legislation,
which exempts added protein and starch from inclusion in the name
of the food where they have a technological purpose and from the
Food Labelling Regulations. The latter require the name of the food
to be sufficiently precise to inform a purchaser of the true nature
of the food and to enable the food to be distinguished from products
with which it could be confused.
The change in the UK legislation is required to bring the UK into
line with European law, so to do nothing is not a realistic option.
FSA could make the necessary legislative changes to overcome this
problem as proposed under option 2, but we would be concerned that
without the associated guidance industry may continue with the current
practice of not labelling these additional ingredients in the name
of the food in the misplaced belief that because they have a technological
function (e.g. proteins bind added water, improve water retention
and hence succulence; starch can help prevent meats from falling
apart on slicing) they do not require labelling in the name.
The guidance is clear and reads well although it will require updating
to take account of the proposed new guidance on clear labelling
on which FSA is also consulting. The complexity of the situation
is reflected by the number of laws which affect this area passed
between 1990 and 2004 referred to in Section 8. Clarity is clearly
desirable in such a complex area.
FSA has asked for views on the proposal to introduce in the guidance
a threshold of 1% for indicating additional protein or starch in
the name of the food. We are not generally in favour of arbitrary
cut off points for labelling purposes, but since the addition of
these substances would in any case have to appear in the ingredients
list, we can see the benefit of clarity about the level at which
the information should appear prominently in the name. Paragraphs
5.18 and 5.19 make the position very clear. We therefore support
this proposal which will help consumers and enforcement authorities
check whether the spirit of the law is being complied with. Over
time, we would hope that courts will take account of the guidance,
although it has no legal force.
We are pleased to see that FSA has underlined in the consultation
and guidance the continuing requirement for protein from a different
species to the meat in question to be labelled. This is most important
for people from different faiths and those who choose to avoid particular
meat products who could be misled.
We agree with the proposed legislative change and support Option
3.
Yours sincerely
Susan Knox
Chairman
|
