Trade Advice Document
Legally there is a difference between meat and 'products containing meat' such as sausages and pies
Although the United Kingdom left the European Union (EU) in 2021, certain pieces of legislation (known as 'assimilated law') continue to apply until such time as they are replaced by new UK legislation, revoked or permitted to expire. This means that our guidance still contains references to legislation that originated from the EU.
In this guide, the words 'must' or 'must not' are used where there is a legal requirement to do (or not do) something. The word 'should' is used where there is established legal guidance or best practice that is likely to help you avoid breaking the law.
This guidance is for England and Wales
The legal term for a product that partially consists of meat is a 'product containing meat' (the traditional term 'meat product' no longer has any legal meaning).
The terms 'meat' and 'regulated product' are defined in legislation, which requires certain types of regulated products containing meat to contain a minimum amount of meat.
There are also further requirements when the product contains particular types of meat. These are collectively known as reserved descriptions.
WHAT ARE 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".
The following are not meat-containing products:
- raw meat with no added ingredients (except proteolytic enzymes)
- uncooked poultry with no added ingredients except additives, water, self-basting preparations or seasonings
- fat with no meat
'Meat' is defined as "the skeletal muscle of mammalian or bird species recognised as fit for human consumption with naturally included or adherent tissue" (fat and connective tissue).
Mechanically separated meat and heart, tongue, etc are not meat.
A certain amount of fat and connective tissue, up to set limits, are considered to be meat. Any fat and connective tissue over the set limits will not be meat and, if the permitted levels are exceeded, you will have to declare added fat and/or connective tissue in the product's ingredients list.
Type of meat | Pork | Birds and rabbits | Beef, lamb and other species |
---|---|---|---|
Fat | 30% | 15% | 25% |
Connective tissue | 25% | 10% | 25% |
MAKING YOUR OWN PRODUCTS CONTAINING MEAT
If you make your own products, ensure that you know, and stick to, the exact recipe and make due allowance for variations in mixing and/or manufacture.
COMPOSITIONAL REQUIREMENTS FOR CERTAIN PRODUCTS CONTAINING MEAT
Some meat-containing products must have a minimum amount of meat and some can only include certain types of meat. These are summarised in the table below.
If your product does not contain enough meat, or contains a different type of meat to that allowed, you cannot use the description given in the 'Name of product' column below. For example, a beef burger must contain a minimum of 62% meat; if it has less than 62% it cannot be called a beef burger.
Please note:
- X is used to refer to a specific type of meat, such as beef in beef burgers, pork in pork pies, etc
- meat content for numbers 7-13 must be calculated by reference to the weight of uncooked ingredients
- 'meat' includes cured meat
Name of product | Pork only | Birds and rabbits only | Beef, lamb and other species, or other mixtures of meat | Type of meat used |
---|---|---|---|---|
1. Burger | 67% | 55% | 62% | If described as an X burger, the amount of X must be at least equal to the minimum required meat content |
2. Economy burger | 50% | 41% | 47% | If described as an X economy burger, the amount of X must be at least equal to the minimum required meat content |
3. Hamburger | 67% | N/A | 62% | All pork, all beef or a mixture of pork and beef |
4. Chopped X | 75% | 62% | 70% | N/A |
5. Corned meat, corned X | 120% | 120% | 120% | All the meat must be X. Total fat content must not exceed 15% |
6. Luncheon meat, luncheon X | 67% | 55% | 62% | N/A |
7. Meat pie, meat pudding, X pie, X pudding, game pie, weighing more than 200 g | 12.5% | 12.5% | 12.5% | N/A |
8. Meat pie, meat pudding, X pie, X pudding, game pie, weighing not more than 200 g and not less than 100 g | 11% | 11% | 11% | N/A |
9. Meat pie, meat pudding, X pie, X pudding, game pie, weighing less than 100 g | 10% | 10% | 10% | N/A |
10. Scottish pie, Scotch pie | 10% | 10% | 10% | N/A |
11. Meat and something else pie, meat and something else pudding, X and something else pie, X and something else pudding | 7% | 7% | 7% | N/A |
12. Something else and meat pie, something else and meat pudding, something else and X pie, something else and X pudding | 6% | 6% | 6% | N/A |
13. Pasty, pastie, bridie, sausage roll | 6% | 6% | 6% | N/A |
14. Pork sausage (but not pork liver sausage or pork tongue sausage), pork link, pork chipolata, pork sausage meat | 42% | N/A | N/A | N/A |
15. Sausage (but not liver sausage or tongue sausage), link, chipolata, sausage meat | 32% | 26% | 30% | N/A |
SALES TO CATERERS AND OTHER FOOD BUSINESSES
These must comply with the same minimum standards as products sold directly to consumers.
UNCOOKED PRODUCTS CONTAINING MEAT
Certain parts of the carcase of mammalian species may not be used in uncooked meat-containing products (brains, feet, small and large intestine, lungs, oesophagus (gullet), rectum, spinal cord, spleen, stomach, testicles, udder). Uncooked intestines may be used as casings for sausages. If sausage casings are inedible then this must be stated.
SPECIFIED RISK MATERIAL (SRM)
SRM is the parts of an animal that represent the highest risk of carrying disease.
The sale of SRM and the sale of any food containing SRM for human consumption is banned, as is the use of SRM and the sale of SRM for use in the preparation of food for human consumption.
For cattle, SRM varies according to whether it originated in the UK and its age, but generally includes the skull (including brain and eyes), tonsils, spinal cord, thymus, spleen and intestines. For sheep and goats there are also differences for age, and for UK and non-UK animals, but generally SRM includes the skull (including brain and eyes), tonsils, spinal cord and spleen.
MEAT CONTENT DECLARATION (QUID)
Any ingredient mentioned in the name of the food, emphasised on the food, or generally associated with the food must be given a 'quantitative ingredient declaration' (QUID), which states how much of the ingredient is in the food in the form of a percentage of the entire product. If specifying the species or cut of the meat (for example 'Pork sausages') you will need to declare how much is present.
Detailed information on the QUID declaration for products containing meat can be found in 'Labelling of prepacked foods: QUID'.
The QUID requirements for products containing meat apply equally to products that are non-prepacked, prepacked or prepacked for direct sale.
MECHANICALLY SEPARATED MEAT (MSM)
Mechanically separated meat is the product obtained by removing meat from bones after boning, or from poultry carcases, using mechanical methods that cause the muscle fibre structure to be lost or changed.
MSM is not meat and will not count towards the meat content of the product. If the product contains MSM it must be declared separately in the ingredients list in the format 'mechanically separated meat' followed by the animal species it comes from.
FORMED MEAT
Any product containing meat that looks like a single piece of meat, but is actually several pieces joined together with other ingredients, needs to be labelled with the statement 'Formed meat'.
ADDITIVES
The types and amounts of additives, such as colours and preservatives, that can be used in products containing meat are strictly controlled. Some are banned, whereas others may be limited to certain foods, and in certain amounts.
For more detail on colours please see 'Colours in food'; there is also information and business guidance on additives and E numbers on the Food Standards Agency website. Please ask your local Trading Standards service if you require further details.
NAME OF THE FOOD
If any meat-containing product contains added proteins from a different animal it must be stated in the name of the food (for example, 'Beef meatballs with added pork protein').
If you produce or sell uncooked cured or uncured meat-containing products that contain more than 5% water and have the appearance of a cut, joint, slice, portion or carcase of meat, you must include the words 'added water' in the name of the food (for example, 'Bacon with added water').
In most cases prepacked foods must be labelled with a descriptive name that accurately describes the food. You will need to decide on a case-by-case basis whether any added ingredients will need to be stated in the descriptive name in order for the product to be accurately described.
PROTECTED FOOD NAMES
Certain food products, including Traditional Cumberland Sausage, Cornish Pasty and Melton Mowbray Pork Pie, have been accredited with protected status. Any products using this name must comply with the compositional (what it contains) and/or origin (where it is made) requirements. More information on protected food names is available on the GOV.UK website.
MINCED MEAT
Minced beef, minced turkey, etc that contains no additives or other ingredients is 'meat' rather than a 'product containing meat' and the requirements of this guide do not apply; for more information see 'Labelling of meat and products containing meat'. Minced beef particularly has specific labelling requirements, including the country in which the animal was slaughtered, the country in which the product was minced and prepared, and a traceability reference number or code; see 'Labelling of beef'.
However, products that use mince as an ingredient (and, therefore, consist of more than just minced meat) are 'products containing meat' and must follow the requirements outlined in this guide.
TRADING STANDARDS
For more information on the work of Trading Standards services - and the possible consequences of not abiding by the law - please see 'Trading Standards: powers, enforcement and penalties'.
IN THIS UPDATE
No major changes.
Last reviewed / updated: June 2024
Key legislation
- Food Safety Act 1990
- assimilated Regulation (EU) No 1169/2011 on the provision of food information to consumers
- Food Information Regulations 2014
- Food Information (Wales) Regulations 2014
- Products Containing Meat etc (England) Regulations 2014
- Products Containing Meat etc (Wales) Regulations 2014
Please note
This information is intended for guidance; only the courts can give an authoritative interpretation of the law.
The guide's 'Key legislation' links may only show the original version of the legislation, although some amending legislation is linked to separately where it is directly related to the content of a guide. Information on changes to legislation can be found on each link's 'More Resources' tab.
© 2024 itsa Ltd.