There are a number of legal requirements regarding the labelling and composition of fresh meat, cooked meat and meat-containing products. Food for sale to consumers needs varying degrees of labelling. Beef, veal, pork, mutton, lamb, goat meat and poultry meat have specific legislation governing their labelling. Specified meat-containing products have a legal definition and very specific labelling requirements. You also need to take care when using such terms as ‘smoked’ and ‘traditional’ as these are also subject to legal and restricted definitions.
Fresh meat in general
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 (England) Regulations 2013 and the equivalent regulations for Wales. Sulphur dioxide is only permitted in burger meat containing a minimum 4% rusk or vegetable content, or sausages, and at a set level of 450 mg/kg. As it is an allergen, its presence must be declared. For further information on allergen labelling see ‘Food allergens and intolerance’.
If any meat-containing 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-containing products with the appearance of a cut, joint, slice, portion or carcase of meat, that contain more than 5% water, you must include the words ‘added water’ in the name of the food.
If the meat-containing product contains any other added ingredients apart from these, whether or not these need to be included in the name of the food should be determined on a case-by-case basis in accordance with Regulation (EU) No 1169/2011 on the provision of food information to consumers.
A limited number of types of fresh meat have ‘protected designation of origin’ status, based on breed, geographical origin or farming method. More information on protected food names, including a list of UK registered names, is available on the GOV.UK website.
Fresh, chilled and frozen beef and veal
Information that must be provided on all beef and veal products, whether fresh, chilled or frozen:
- a reference number or code identifying the specific animal or group of animals from which the beef was derived
- the name of the country in which the animal or group of animals were born**
- the name(s) of all countries in which the animal or group of animals were raised**
- ‘Slaughtered in: [name of country]’**
- approval number of the slaughterhouse*
- ‘Cutting / cut in: [name of country]’
- approval number(s) of the cutting plant(s)*
Those points marked with * above are not required for retail sale to the public of loose (non-prepacked) beef or veal products.
Where animals have been born, raised and slaughtered in the same country, those points marked with ** above can be replaced by ‘Origin: [name of country]’. Where compulsory information is not available for meat imported from a non-EU country, the labelling must show at least the words ‘Origin: non-EU and slaughtered in [name of country]’. You should also show a traceable reference number or code if the meat is cut or repackaged after import.
Prepacked cut beef and veal
Prepacked cut beef and veal can be sold with meat from a maximum of three slaughterhouses or cutting plants in the same package. The labelling on these packages must show:
- slaughterhouse approval number and country of slaughter for each of the relevant countries of origin. Shown as: ‘Animals in the group slaughtered in [name of country]’
- country of cutting and cutting plant approval number for each appropriate country of cutting. Shown as: ‘Cutting of meat in batch in [country of cutting]’
Non-prepacked cut beef and veal
For non-prepacked beef and veal, the requirements are the same regarding mixing batches from a maximum of three slaughterhouses or cutting plants. The information that must be provided to the final consumer is country of birth, rearing, slaughter and cutting. This information should be provided in such a way that consumers can clearly see what information relates to what meat without confusion. Meat from different countries must be clearly separated in the display. Operators must keep a daily, dated record of licence numbers of the slaughterhouses and cutting plants relating to the meat for sale. This must be shown to consumers on request.
Minced beef must be labelled with the following:
- traceability reference number or code
- country of slaughter
- country of mincing / preparation
- country of origin (from birth to slaughter) if different to country of mincing
Minced beef from two or more countries of origin cannot be mixed by cutting plants. Minced beef can be mixed with offal from the same country; it must then be marked with all compulsory information. ‘Offal’ means fresh meat other than that of the carcase, including viscera (organs of the thoracic, abdominal and pelvic cavities, as well as the windpipe and gullet) and blood.
Minced meat should not contain more than 25% fat. If you describe your product as ‘lean’ it should not contain more than 7% fat. There is no fat limit set for ‘extra lean’ mince but if you describe your product as such it should contain considerably less than 7% fat. Where a meat is named (for example, minced beef) then no other meats can be present.
No additives can be used in minced meat. Please note that products that contain minced meat as an ingredient are ‘products containing meat’ rather than ‘meat’ and may contain certain additives. For more information on the requirements for products containing meat, see ‘Composition of products containing meat’.
Trimmings must be labelled with the following:
- country of slaughter
- country or production
- countries of birth and rearing
If all of the above are the same country, the food label may read ‘Country of origin: [name of country] (where birth, rearing and slaughter took place)’.
Beef and veal from animals under 12 months old must be categorised at slaughter with reference ‘V’ for animals under eight months old, and ‘Z’ for animals between eight and 12 months old. They must be marketed according to their designated names in the EU. In the UK, animals with a ‘V’ code under eight months old are required to be described as veal. Animals with a ‘Z’ code aged between eight and 12 months must be described as beef. These requirements also apply to offal.
Meat and offal from animals under 12 months old must be labelled accordingly (‘Age on slaughter: up to 8 months’ or ‘Age on slaughter: 8-12 months’) at each stage of production or sale, but this can be abbreviated to ‘V’ or ‘Z’ until retail to the final consumer.
Offal must also be described appropriately – for example, ‘calves’ liver’ may only be used to describe liver from animals under eight months old. Offal from different aged animals may be mixed, but must be labelled with the appropriate information for both sources. Beef or veal meat from ‘V’ and ‘Z’ coded animals may not be mixed.
Cooked meat and products containing meat
Meat-containing products are regulated products; all regulated products are covered by the Products Containing Meat etc (England) Regulations 2014 and the equivalent regulations for Wales.
A ‘regulated product’ is defined in the Regulations 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 [cheeks, which are considered to be meat]), the carpus [lower forelimb], the tarsus [lower hindlimb], or the tail of any mammalian or bird species recognised as fit for human consumption”.
Meat-containing products that are sold loose must be accompanied by:
- a food label with the name of the product
- a QUID declaration for any meat-containing ingredients
- details of any irradiated ingredients
- the words ‘added water’ in the name of the food (for example, ‘Bacon with added water’), if the products contain more that 5% water
Additionally, many meat-containing products – such as sausages, burgers, pasties and pies – are subject to compositional requirements. When producing products that contain meat, you will need to ensure that your recipe and manufacturing method produces goods that comply with their legal definition, with particular regard to meat content. Recipes should be written down and you should check all ingredients – spice blends, for example – for the presence of any allergens, which must be declared.
Meat is legally defined as skeletal muscle with specified amounts of adherent tissue (connective tissue and fat); it does not include offal. Mechanically separated or mechanically recovered meat (MSM or MRM) cannot count as part of the meat content; the cell structure of the meat is altered during the process of recovery, meaning that it no longer meets the legal definition of meat. 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 different methods currently used to work out meat content from a cut of meat:
- ‘visual lean’. This is the simplest method and is most suitable for smaller retail outlets
- ‘CLITRAVI analysis’
- ‘nitrogen testing’ (for single species only)
The last two methods are only suitable for manufacturers that know the analytical values of the nitrogen content of the cuts of meat that they use. Products containing meat only need to be labelled with their country of origin if it would be misleading not to do so.
Fresh, chilled and frozen pig, sheep, goat and poultry meat
Information that must be provided on all fresh, chilled and frozen pork, lamb, mutton, goat meat and poultry meat supplied to mass caterers or the final consumer:
- ‘Reared in: [name of Member State or non-EU country; where an animal has been reared in more than one country, the table below explains what should appear on the labelling]’
- ‘Slaughtered in: [name of Member State or non-EU country]’
- a reference number or batch code identifying the specific animal or group of animals from which the meat was derived
‘Member State’ means Member State of the EU; bear in mind that the UK is no longer a Member State and you must not refer to it as such.
Minced meat and trimmings
‘Trimmings’ are defined as small pieces of meat produced exclusively during trimming operations, when boning carcases or cutting up meat. Minced meat and trimmings are permitted to be labelled in one of the ways below if more specific information as to their origin is not available:
- ‘Origin: EU’, if the minced meat or trimmings derive exclusively from animals born, reared and slaughtered in different Member States
- ‘Reared and slaughtered in: EU’, if the minced meat or trimmings derive exclusively from animals reared and slaughtered in different Member States
- ‘Reared and slaughtered in: non-EU’, if the minced meat or trimmings derive exclusively from meat imported into the EU
- ‘Reared in: non-EU’ and ‘Slaughtered in: EU’, if the minced meat or trimmings derive exclusively from animals imported into the EU for slaughter and slaughtered in one or more different Member States
- ‘Reared and slaughtered in: EU and non-EU’, if the minced meat or trimmings are derived from animals reared and slaughtered in one or more different Member States and from meat imported into the EU; or from animals imported into the EU and slaughtered in one or more different Member States
Food business operators at each stage of production and distribution of the meat, including packaging and labelling it for the final consumer, are required to have an identification and registration system in place. In particular, a record needs to be kept of the arrival and departure from the food business establishment of animals, carcases or cuts (as appropriate) to ensure a correlation between such arrivals and departures. The purpose is to ensure that the information provided to the mass caterer or final consumer corresponds to that relating to the batch where the meat came from.
