Food labelling for butchers
A brief guide to the essentials of food labelling and composition for butchers
This guidance is for England
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 very specific legislation governing their labelling, while pork is not subject to the same sort of legal requirements. 'Meat product' has a legal definition and very specific labelling requirements. Butchers also need to take care when using such terms as 'smoked' and 'traditional' as these are also subject to legal and restricted definitions.
In the guide
- Fresh meat - general
- Fresh meat - beef and veal
- Fresh meat - pork
- Cooked meat and meat products
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 instance, sirloin steak, frying steak, loin chops, or mutton mince. Meat that has been treated with proteolytic enzymes must be described as 'tenderised'.
The name of the food must also be accompanied by the category of any additives that have been used. Only permitted additives from categories in the list below may be used:
- flavour enhancer
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. 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.
When considering additive declarations, bear in mind the ingredients of any spice mix, glaze or additional ingredients that you may have used, for instance in stuffings. If herbs or any other products you have used have been irradiated, you must also include this on the label.
The labelling should also declare any added water in excess of 5%, or in excess of 10% for uncooked cured meat.
You do not have to list other additional ingredients used solely as a seasoning, garnishing or gelatinous coatings (except for any additives or irradiated ingredients they contain, as above). Other additional ingredients do not have to form part of the name of the food for shaped minced meat products, such as burgers or meatballs made on your premises and sold loose.
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. Please see 'Labelling of beef'.
Meat products are defined in the Meat Products (England) Regulations 2003 as a food that 'consists of meat or which contains as an ingredient, or as ingredients, any of the following: meat; mechanically recovered meat; or, from any mammalian or bird species recognised as fit for human consumption, heart, tongue, the muscles of the head (other than the masseters), the carpus, the tarsus, or the tail'.
Meat products must be accompanied by a label with name of the product, details of any additives, irradiated ingredients and added water in excess or 5%, as for fresh meat. Additionally, many meat products are subject to compositional requirements, such as sausages, burgers, pasties and pies. Detailed information is provided with regard to this in 'Composition of meat products'.
When producing meat products, you will need to ensure your recipe and manufacturing method produces goods which comply with their legal definition, with particular regard to meat content. More information on making and selling meat products is available on the Food Standards Agency website. This guidance also provides clear advice about what you must declare as the percentage of each type of meat in your product (QUID).
Meat is defined as skeletal muscle with specified amounts of associated 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.
There are a number of requirements for sales and descriptions of eggs. Please see 'Retail sale & labelling of eggs' for information about this subject. Information on trade regulations for eggs is also available on the GOV.UK website.
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 which have not been smoked but containing '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
- Meat Products (England) Regulations 2003
- Beef and Veal Labelling Regulations 2010
- Food Additives, Flavourings, Enzymes and Extraction Solvents (England) Regulations 2013
This information is intended for guidance; only the courts can give an authoritative interpretation of the law. Any legislation referred to, while still current, may have been amended from the form in which it was originally enacted. Please contact us for further information.
Last reviewed/updated: November 2013